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Posted by u/hash872 3 years ago
Ask HN: Why on Earth does Europe have 3 month notice periods to switch jobs?
I'm an American looking to hire developers in the EU for one of our business units. I've been absolutely astonished by European employment 'contracts' that require a 3 month (!) or longer (!!) notice period to quit a job. It's difficult for me to understand how this isn't indentured servitude, especially in a region known for its stronger labor protections than the US. Here in America employees customarily put in 2-3 weeks of notice, maybe 4- but it's purely a courtesy, and technically the employee could leave literally anytime they want.

A contract stating that you're not allowed to leave without 3 months of notice seems extraordinarily restrictive. (What happens if you ignore it?) I can't imagine how a future employer can wait a full quarter to just hire someone- so this must greatly restrict labor mobility and hence wages. How is this legal, in the famously pro-labor EU?

ggeorgovassilis · 3 years ago
> by European employment 'contracts'

With great variations between member states. Germany has long notice periods, Greece has as short as 2 weeks notice.

> how this isn't indentured servitude

Labour law extends similar protections to employees. A long notice period simply levels the playing fields by returning some protection to employers. That's why in the EU there aren't mass layoffs like in the US right now, or riots, or mass shootings.

> (What happens if you ignore it?)

Maybe nothing, depends on how litigious the employer is. Usually a shorter notice period can be negotiated, eg. by agreeing to some un/pre-paid post-departure consulting for the previous employer.

> I can't imagine how a future employer can wait a full quarter

It's about planning. I wouldn't want to work for an employer who is hiring in panic because they haven't foreseen labour needs. I'd be afraid that they'd let me go as easily as they have hired me.

> so this must greatly restrict labor mobility

Yes

> and hence wages

That is why you are trying to hire in Europe, aren't you?

> How is this legal, in the famously pro-labor EU?

Because it is literally the law.

pc86 · 3 years ago
And otherwise insightful comment making the absolutely bizarre connection between long employment notice periods and riots and mass shootings.
131012 · 3 years ago
I think for many of us outside the US, your culture of dog eat dog and I owe nothing to nobody except my sacred duty to get rich is the root of your social problems.
pjc50 · 3 years ago
This is a massive derail, but mass shootings are an almost uniquely American phenomenon, and they are a policy choice - delivered by a uniquely dysfunctional politics that prizes ideology over actual outcomes. The outcome being protected here is "employers may not fire employees at zero notice", with the symmetry that this also applies to the employee.
ivan_gammel · 3 years ago
More social security means more stable and less violent society, so it is an exaggeration but it is not wrong.
ted_bunny · 3 years ago
For what it's worth, one of the main contributing factors to terroristic activity is lack of economic prospects. Similar enough that it rings true to me. Also, consider that pre-Columbine, the cultural template for mass shootings was someone disgruntled about their workplace.
908B64B197 · 3 years ago
> riots

Has this person ever been to France or Greece?

> mass shootings

In foreign countries without second amendment rights criminals just ram trucks into people instead. Since no guns are involved, these don't get reported as "mass shootings", not that it would bring any comfort to the victims and their families.

https://en.wikipedia.org/wiki/2016_Nice_truck_attack

https://en.wikipedia.org/wiki/2016_Berlin_truck_attack

https://en.wikipedia.org/wiki/2018_Toronto_van_attack

xwowsersx · 3 years ago
> > How is this legal, in the famously pro-labor EU?

> Because it is literally the law.

Ha, fair enough. I believe OP meant to ask and should have asked something along the lines of: "How is this the law in the famously pro-labor EU?"

rob74 · 3 years ago
If you have a longer notice period for the employers, it's only fair to have the same for the employees too. After all, if your company has to search for a replacement, and the prospective candidates are currently employed with the same notice period, they have to start looking as soon as you hand in your notice...
pastacacioepepe · 3 years ago
> (What happens if you ignore it?)

In the EU country I live in employees have 30 days of notice and the employee has to pay the employer for each missing day of required notice. Employees generally don't pay anything anyway, as they mature several additional "bonuses" (13th and 14th month, severance pay) during their employment and the missing notice payment can be detracted from those.

hash872 · 3 years ago
Employment contracts will prevent mass shootings?
pjc50 · 3 years ago
People are arguing this in the comments, but: no, obviously not, mass shootings are not directly anything to do with employment, but they are a policy choice which Europeans and Americans cannot understand each other over.
jeromegv · 3 years ago
In general Europe tends to provide a stronger social net. Not just labor laws but what happens when you are out of job, have disability, etc. Some might argue that the poor are less poor and the rich are less rich (less disparity) which overall contributes to a better social climate and better mental health.

Would you rather be sick and poor in the US or in a more socialist country? Of course there's nothing like being wealthy in the US but if you fall behind in the US, there's definitely less support for you and might make people more.. desperate. US also has the highest incarcerated rate in the western world for a reason.

Those are all opinions and I have nothing to quote, but it's hard to argue that there is a strong difference in how societies are structured and what support they provide to their citizens to live a better life

martin_a · 3 years ago
Social security nets probably do.
ggeorgovassilis · 3 years ago
Employment does
PaywallBuster · 3 years ago
half the mass shootings are done by young/students?

South europe countries have ~ 50% youth unemployment and very little prospects however there's no mass shootings?

cscurmudgeon · 3 years ago
1. There are layoffs in EU but they are not click worthy as those in Silicon Valley.

https://sifted.eu/articles/startup-tech-company-layoffs-2023...

piva00 · 3 years ago
At least in Sweden (and I believe Germany is similar) there are no layoffs as you see in the US. In Sweden an employer might extend an offer to buy you out of your employment contract, which you can deny and continue to be employed. If they want to do layoffs they will have to follow LAS which has a few provisions on how it should be done, including a LIFO order for who gets shafted, and any positions considered "redundant" not being able to be hired at all for a few months (I believe it's 6 months but I might be wrong).
ad404b8a372f2b9 · 3 years ago
Most people don't want to be labor mobile, they want to be labor secure.

Generally you can agree with your employer to waive the notice period. Often people will also take their accumulated vacation days at that time. Some collective labor agreements also specify that employees can take so many days off a month to look for a new job.

londons_explore · 3 years ago
> Most people don't want to be labor mobile, they want to be labor secure.

I suspect that even though most individuals want to be labor secure, most people would actually be better off with more mobility instead.

You wouldn't mind being laid off if you were pretty certain you could get a new job with a similar salary within just a few days. The only reason being laid off is so stressful is because there isn't sufficient mobility, and it's likely it will be many weeks or months till you find a new employer.

I'd kinda like to see an 'employer of last resort', where the government guarantees to employ anyone anytime. That should at least take away much of the fear of being laid off, even if few people actually use the service.

ad404b8a372f2b9 · 3 years ago
That's essentially what France does (and the U.S I think, to some extent with welfare?), you have a right to the "allocation chômage" which is a monthly payment from the government and your job is to find a new job.

But I don't believe in these perfectly efficient systems, like the one you describe, in which as long as we remove friction everyone can do what they want. Humans are not robots, they need emotional and social stability to thrive. A job comes with a location, social bonds, an expertise, habits ... You can't swap one for another and call it good as long as the paycheck stays the same.

freitzkriesler2 · 3 years ago
One of the many myriad of problems I saw while living in Europe.

Great labor protections! Very few job openings.

There's always a flip side to the good things online Europeans like to brag about.

poisonborz · 3 years ago
This is the right answer. Not everyone is a SWE with endless mobility and 1 week job searches.
jaclaz · 3 years ago
I believe you will need a lot of de-astonishing if you plan to manage your EU business unit.

Three months is not "EU", it is more likely a Law of a specific country in EU.

Typically (but again it may depend on country) you can of course leave, but without an agreement on the lack of advance notice the employer may keep the equivalent of your pay for the period.

ElfinTrousers · 3 years ago
Another iteration of the ancient story: "American shocked to find rest of world operates differently in some ways".
kube-system · 3 years ago
It’s less of a shock that it’s different and more of a shock that it’s anti employee
pjc50 · 3 years ago
Bidirectional notice periods tend to be contract, rather than statute. That is, it exists because the country has not legislated against it, and it's by convention included in the contracts.
p_l · 3 years ago
Depends on country - Polish employment law has "notice period" be bidirectional asa statute unless a gross abuse happened (enumerated in another section of employment law). Shortening notice period is a bidirectional contract where the employee may forfeit owed wages for shorter notice period.
polishrandomguy · 3 years ago
What people don't seem to realize is that you absolutely CAN leave anytime that you want, without that notice period, if both you and your employeer agree on doing do. It is pro-employee policy, as it gives you time to peacefully search for other job and not be left without any wage to support yourself and your family. It also prevents employees from leaving without preparing next person that will take over their responsibilities, and gives time to the employeer to actually find your replacement if they need to.

It's not an anti-employeer, nor anti-employee policy, and it just goes to show how less of a friendly workplace USA market has.

poisonborz · 3 years ago
I've never the notice period not happening. And honestly can't imagine why someone would want it (except rare cases like abuse or new salary massively better).

- Other companies are absolutely used to this period, and you already sign the contract with the start time that much ahead - there is no need to haste. - If there was a workplace conflict, most companies just give this as a "free holiday" - rather than go through the legalities of making it shorter. - Nobody expects much performance during notice period, you are not taken into long term planning, but you have ample time to give workshops or write documentation about siloed knowledge so it is cozy for both the employee and the employer.

tzs · 3 years ago
> It is pro-employee policy, as it gives you time to peacefully search for other job and not be left without any wage to support yourself and your family.

Wouldn't that also be the case with a short (say two week) or even no notice period?

Simply start your job search before you tell your current employer that you want to leave.

xboxnolifes · 3 years ago
They're talking about the other way around where the employee wants to fire the employee, but now needs to give long notice.
carlosjobim · 3 years ago
> What people don't seem to realize is that you absolutely CAN leave anytime that you want, without that notice period, if both you and your employeer agree on doing do.

I think everybody understands this.

The ethical problem is trying to force an employee to stay and work when they want to leave. It is a basic human freedom.

jedrek · 3 years ago
Hey so fun fact: three month notice periods are standard in Germany because German companies like to have runway to offload and onboard employees.

Germany is famously pro-labor, so you actually have two notice periods: one for the employer (statutory) and one for employees (contract). The two are usually aligned, and only get out of sync when the employee has been working somewhere for a long time. Let's say you have a month-long notice period in your employee contract. You work at your job for 5 years. By that time, the statutory notice period has increased to two months: if your employer wants to fire you, they have to give you two months. On the other hand, if you're the one who wants to leave, you only need to give them one month, per your contract.

Pretty neat.

butler14 · 3 years ago
3 months is reserved for mid- senior roles, and 6 months isn’t uncommon for senior management/board level (often with enforced garden leave)

as a business owner, it protects me from key employees leaving me in the shit and gives me 3 months to replace them

as an employee, it gives them security that I won’t drop them in the shit and they will have 3 months to find a job or risk not being able to pay their bills

It doesn’t seem super complicated

pjc50 · 3 years ago
> contract stating that you're not allowed to leave without 3 months of notice seems extraordinarily restrictive. (What happens if you ignore it?)

You may in theory get sued for the cost of covering for you, but in practice what happens is you lose any outstanding owed you by the employer (wages and payment for holiday not taken).

It's generally considered that this is an employee protection, because it works in the other direction as well. The employer has to give you 3 months notice to end the contract.

(it's not unheard of for people to get the "locked out of your account and building" at the point of resigning, then get paid for the 3 months. This is referred to as "gardening leave")

phphphphp · 3 years ago
Yes, it’s very normal to have long notice periods. An employee absolutely can ignore their notice period if they want* but most respect them because they don’t want to burn bridges. Long notice periods are a companion to much greater worker rights, not in competition with.

Europe’s work culture is very different to America’s in that there’s mutual expectations around the commitment made by the employer and by the employee. All companies understand that to hire someone means to wait for their notice period to expire, so it’s not as if it prevents anyone from opportunities.

* in some places, an employer could pursue the ex-employee for contract violation if they didn’t respect their notice period, and the employee could incur the cost of replacing them in the short term… but it’s very rare and typically only important in the context of high-skill jobs. I’ve never seen it happen.