PIP severance: what to ask for, and when to ask, by country
Severance after a PIP is a statutory right almost nowhere. What you can ask for is set by what a dismissal would cost your employer, and when by the paperwork.
· checked against sourceOne question, two halves, ten answers
Severance after a performance plan is a statutory right almost nowhere this guide covers. In most of the ten countries the law fixes what a dismissed person receives — a tariff, a floor, a risk the employer would rather price than run — and severance is the sum an employer pays to end things by agreement instead, usually in exchange for a release of claims. So what you can ask for is set by two things: what the law would hand you if the employer dismissed you where you work, and what your release is worth to them. Neither is the same at any two borders. And when to ask is set by a third thing, the paperwork and the clock in your country, which decide when the ask carries weight and when the same words are just a wish.
If you are hoping to pass the plan, this is the price list to know before anyone, including you, proposes an ending. Asking in writing what an ending would cost is not a resignation and does not end a plan. What such an approach is worth, and whether it can later be quoted against you, is a question of local law rather than a constant — in the United Kingdom the without-prejudice route is the one employee-side practice names, and this page does not resolve it for the other eight — so take the question to an adviser where you work before you put an ask in writing. If you are planning to leave, it is the list of what to ask for, and the moment at which asking has weight where you live. Read your own country's section, and the two sections before it that hold everywhere.
What is on the table almost everywhere
The asks below recur across the files this page rests on. Which of them cost the employer little, and which are the whole negotiation, differs by country, and the sections below say which is which.
- The money, anchored to what a dismissal would cost the employer where you are — a statutory tariff in Spain, a floor in the Netherlands and France, a risk-priced sum in Germany, a reported range in the United Kingdom, one firm's description of practice in the United States, a contract clause in Canada that may or may not hold — and to what the release of claims is worth. Never to a number somebody received.
- The paperwork that keeps your unemployment benefit. In every country here the words on the exit document decide the benefit: who initiated the ending, what reason it states, and what it is called. This is the one ask that costs nothing and is worth months.
- The separation date. It decides what vests, when notice runs, and, on a US work visa, when the grace period starts. A later date can be worth more than a larger sum.
- Notice paid rather than worked, and in the Netherlands an end date that respects the notional notice period, which the benefit turns on.
- The reference, as agreed wording, a qualified Zeugnis in Germany, or reference language in the United States — with one exception, UK financial services, where the neutral reference largely does not exist.
- Health cover in the United States, as employer-paid COBRA months.
- The scope of what you sign away: claims that exist at signing and no more; carve-outs for statements to authorities; non-disparagement that binds both sides.
- The tax structure, which is an adviser's question rather than arithmetic to do here: the United Kingdom's tax-free threshold on termination payments, Ireland's relief on ex gratia sums, the United States' treatment of severance as wages.
- For a visa holder, the timing of the petition withdrawal, which costs the employer nothing and can be worth weeks.
When the ask carries weight, everywhere
Three rules hold in all ten countries, and they are about time rather than money.
- Never in the room. An offer made in the meeting where the plan is handed over, or where it is declared failed, gets an acknowledgment and a sentence that a written response will follow. The UK employee-side file, the Spanish practice on the finiquito, the German warning against signing in the meeting and the US regulation's clocks all say the same thing from different directions. The wording for that meeting, and the four things to ask for in writing, are on the page about the meetings themselves.
- In writing, and dated. In Ireland an adjudicator held that an exit offer three working days after a plan was activated went to the root of the contract; the interval between two dates was the case. Record the day the plan was issued and the day any package was mentioned, and who was present, wherever you are.
- Before you sign anything. In the United Kingdom a settlement binds only after independent legal advice, and a resignation first throws the leverage away; in Ireland a waiver needs advice to hold; in the United States a worker of 40 or over holds statutory days to consider and to revoke; in the Netherlands and France the signature itself comes with a window to undo it. Signing is the one act every file says to delay.
In the United States
No law requires severance: the Department of Labor says it is a matter of agreement, and the EEOC's guidance says why employers pay it anyway, to reduce the risk of a claim, in exchange for a release. Severance is a price, and what it buys is the release, so what it is worth is set by the file the plan produced, which is why keeping one matters. A release cannot stop you filing a charge with the EEOC, cannot reach claims that arise after signing, and cannot be paid for with wages you are already owed: final pay and, in the states that require it, accrued vacation are yours regardless and are not the deal.
When. At 40 or over the clocks are statutory. A waiver of age claims is valid only if you were given at least 21 days to consider it, 45 where the offer is part of a programme to a group, and 7 days after signing to revoke. The consideration period runs from the employer's final offer and a material change restarts it; the revocation week runs from the day you sign. The regulation forbids inducing an early signature by threatening to withdraw the offer, so a sign by Friday deadline handed to someone of 40 or over cannot make the waiver of age claims valid. Under 40 there is no statutory clock and the release is judged on the whole picture — clarity, time to consider, whether a lawyer was encouraged — so the same written response is the answer without a number to point at.
What to ask for. The low-cost asks first: an undertaking not to contest your unemployment claim, which employer-side guides treat as ordinary deal currency and which the benefit page explains; a later separation date; employer-paid COBRA months — at an employer of 20 or more, COBRA gives 18 months of continuation after a termination for anything other than gross misconduct, at up to 102% of the plan's cost, and the ask is for the employer to pay some of those months rather than for months on top of them; below 20 employees federal COBRA does not apply at all, and what a state scheme offers in its place, where it has one, is outside this guide — reference language and the characterisation of the ending as the employer's decision, on performance rather than conduct; mutual non-disparagement with carve-outs; the release narrowed to claims that exist at signing; bonus and deferred-compensation terms; the option exercise window. On the money, one employee-side firm describes one to three weeks of pay per year of service as common practice, which is a description and not an entitlement.
At the named employers, the doors are the timing. Amazon's ladder declines at every stage, so the moment to weigh the package is before choosing a door, not after losing an appeal. Microsoft's offer is a fixed sixteen weeks, presented once, reportedly with five business days to take it. Meta's reported 2025 terms — sixteen weeks plus two per year of service, with six months of health cover — are anchors, never promises. Every figure at every one of them is reported, not official.
In Canada
What the law hands a dismissed person here is notice of termination, or pay in lieu of it, and that is the anchor everything else prices off. An employer that cannot prove just cause owes it whatever the plan said and whether or not you failed it, and cause for poor performance is a high bar that most employers do not try to clear. So a package at the end of a plan is the price of a release of your claims, and not a verdict on your work.
How much notice is the whole question, and it is usually decided before any negotiation starts, by the termination clause in the agreement you signed on your first day. Where that clause is enforceable it sets the number, often at the statutory floor of one to eight weeks by length of service, with separate severance pay for longer-serving employees at larger employers. Where it is not enforceable, the common law applies instead: reasonable notice set on your age, length of service, the character of the employment and the availability of comparable work, with only exceptional cases beyond twenty-four months. The gap between those two answers is routinely larger than anything else on the table.
Whether a clause holds is genuinely contested, and the line moved twice. Ontario's Court of Appeal held in 2020 that termination provisions are read as a whole, so a for-cause provision that fails the employment standards legislation takes the without-cause provision down with it. In August 2026 the same court pulled that back, upholding clauses that limit employees to the statutory minimums where the drafting is clear. Material written between those dates overstates how easily a clause is set aside. Nobody should tell you yours is probably void, and nobody should tell you it certainly binds.
Two regimes hand you something no province does. If your employer is federally regulated, or if you are in Quebec with two years of service, reinstatement is a remedy the adjudicator can order — which changes what your release is worth to the employer rather more than a notice argument does.
When. Before you sign a release, and one date makes that unusually concrete. Until 10 October 2026 a temporary measure means separation earnings are not allocated against Employment Insurance, so a package does not push back the start of benefits the way it ordinarily would. That reverses the day it lapses, so the same offer is worth measurably less afterwards. The clocks to challenge the ending itself are shorter than people expect in two of the three regimes, and they are on the deadlines page.
What to ask for. The offer letter in front of an employment lawyer before anything is signed, which is the highest-value step on this page for a Canadian reader and the one most often skipped. Then the separation language: the ending recorded as a dismissal for performance rather than for cause, and written confirmation that your employer will not assert misconduct, both of which cost it little and decide the benefit. Then a later last day, agreed reference wording, notice paid rather than worked, and the release narrowed to claims that exist at signing. If you hold a closed work permit, put the date ahead of the money, for the reason in the section below.
In the United Kingdom
There is no statutory severance for a capability dismissal. What exists is a settlement agreement, and the employee-side file this section rests on argues that the start of a plan is one of the most common triggers for one. Its reported range — an opening position around six months' gross pay, employers countering at three and settling at four to five — is one firm's account of its own practice and is stated here as that, never as what you will get.
When. Three moments carry weight. At the start, if HR opens with a without-prejudice or protected conversation offering money to leave: the employee-side file this rests on argues that where there was no prior process and no earlier notice of a problem that protection can fail, putting the offer on the record and supporting the argument that the outcome was decided in advance — and marks the admissibility carve-outs as needing confirmation against current law, so treat it as a question for an adviser rather than as settled. Mid-plan, on your own initiative: a without-prejudice letter proposing a quiet exit for a package — notice paid in lieu, an agreed reference, and a sum roughly equal to what running the plan would cost the employer in salary. And after failure or dismissal: documented procedural failings support negotiation then too, inside the tribunal clock. Never respond to an offer in the meeting; say a written reply will follow, and reply after advice.
What to ask for. The ending papered as a capability termination on the employer's initiative, with no misconduct language anywhere in the agreement or the reference — because a settlement sits in genuinely unsettled ground for benefit purposes and the safest framing is the one that reads as dismissal. A call to Jobcentre Plus about the proposed structure before signing. Advice on the tax-free threshold for termination payments and on timing across tax years, since a lump sum can switch off Universal Credit while New Style JSA stays claimable. And a settlement agreement binds only after independent legal advice, so a resignation before one is signed gives the leverage away for nothing.
In financial services the order of the asks inverts. Classification is worth more than money: regulatory references are mandatory, cover six years, must be given however the employment ended and cannot be contracted away, so the ask is the reference wording that is permissible, what will be recorded about any open investigation, and the treatment of deferred compensation, before the cash. This is the one section here where the general advice to see an employment lawyer is not enough: take a regulated-role exit to a solicitor who does financial services employment work specifically, before you agree anything.
What a UK settlement agreement is, and what makes one binding
The instrument the section above calls a settlement agreement has a statutory definition, and it is worth reading as one. A settlement agreement is a contract in which you give up the right to bring named claims, normally in exchange for money and an agreed ending. It is also the only lawful route to signing those rights away: section 203(1) of the Employment Rights Act 1996 makes void any agreement purporting to exclude a provision of that Act, and s. 203(2)(f) carves out one exception, an agreement meeting the conditions in s. 203(3).
Read those as conditions rather than as formalities. A document missing any of them does not bind you, whatever it is headed and whoever has signed it. Under s. 203(3) the agreement must be in writing; it must relate to the particular proceedings; you must have received advice from a relevant independent adviser on its terms and effect, and in particular on its effect on your ability to pursue those proceedings; that adviser must be covered by insurance or professional indemnity; the agreement must identify them by name; and it must state that the conditions regulating settlement agreements under the Act are satisfied.
Who may advise you is defined. Who pays for it is not. S. 203(3A) lists a qualified lawyer, a trade union official certified by their union, a certified advice centre worker, and anyone in a category the Secretary of State designates. Nothing in the Act obliges your employer to fund that advice. ACAS states the position directly: the employer "should consider offering to pay the cost of any independent advice. They do not have to do this." A contribution is ordinary practice, is worth asking for early, and is worth naming a figure for. It is not an entitlement, and the belief that it is may be the most commonly overstated claim on employee-facing sites in this jurisdiction.
The practical consequence runs the other way from how it is usually told. The advice requirement is not a hurdle the employer puts in front of you. It is the thing that makes your signature worth buying, which is why a resignation tendered before an agreement is signed gives away the only asset in the negotiation.
The protected conversation, and the claims it does not cover
The other half of the UK arrangement is section 111A of the Employment Rights Act 1996, in force since July 2013, which is what an employer means by a protected conversation. It makes evidence of pre-termination negotiations inadmissible, and s. 111A(2) defines those as any offer made or discussions held, before the employment ends, with a view to ending it on agreed terms.
What it does not do is the part that matters, and the name is what obscures it. S. 111A makes those negotiations inadmissible in proceedings on a complaint under s. 111, the ordinary unfair dismissal claim, and in nothing else. It does not reach a discrimination claim, an automatically unfair dismissal claim, or a claim for breach of contract or wrongful dismissal. The older common-law without-prejudice rule is a separate protection with a separate condition: it needs a dispute already in existence, where s. 111A does not.
Two further carve-outs sit inside the section. Under s. 111A(3) it does not apply where, on your case, the circumstances are such that a statutory provision requires you to be regarded as unfairly dismissed, which is the automatically unfair route. Under s. 111A(4) a tribunal may admit anything said or done that was improper, or connected with improper behaviour, to whatever extent it thinks appropriate.
Improper behaviour is for a tribunal on the facts, and the ACAS Code of Practice on settlement agreements gives the list at its paragraph 18: harassment, bullying and intimidation, including offensive words or aggressive behaviour; physical assault or the threat of it; other criminal behaviour; victimisation; discrimination on a protected ground; and undue pressure. Undue pressure has two worked examples, and both are common in practice:
- Not allowing the time to consider that the Code sets out below.
- Saying you will be dismissed if you refuse, said before any disciplinary or capability process has begun.
Two things the Code is equally clear are not improper, and reading them backwards is its own mistake: an employer may set out its reasons for proposing a settlement agreement, and may say what the likely alternative is. An offer is not itself misconduct, and treating it as one wastes the argument.
Where a plan sits in the settlement-agreement timeline
A performance improvement plan is not a stage of the settlement process, and no rule connects them. What connects them in practice is that a plan is the moment an employer has committed to a documented position, which is the moment both sides can price an ending. The employee-side account this page rests on puts the start of a plan among the most common triggers for an agreement being proposed at all.
Four fixed points are worth holding, in the order you are likely to meet them.
- Before or at the plan meeting. An offer arriving here, with no prior notice of a performance problem and no process started, is the case in which the undue-pressure example above is closest at hand. Acknowledge it, say a written reply will follow, and leave.
- The written terms, and the ten days that run from them. Paragraph 12 of the ACAS Code recommends a minimum of ten calendar days to consider the proposed formal written terms and take independent advice, unless both sides agree otherwise. It is a recommendation rather than a limitation period, and its weight comes from paragraph 18: refusing reasonable time is an example of the pressure that costs an employer the protection of s. 111A(4). Record the date the full written terms arrived, because that is what the ten days should run from.
- Mid-plan, on your own initiative. The section above sets out what to ask for and why the ask has weight here.
- After failure or dismissal, inside the tribunal clock, which is the hard deadline in this sequence and the only one of the four that is.
Paragraph 13 of the Code adds one thing worth using at every point above: employers should allow you to be accompanied at the meeting by a work colleague, a trade union official or a trade union representative. The Code states it as good practice rather than as the statutory right that attaches to a disciplinary or grievance hearing, so it is asked for rather than asserted, and it is rarely refused.
A typical exit package, in the order the asks are usually resolved:
- Notice, paid in lieu rather than worked.
- An ex gratia sum, which is the negotiated part and the one with no floor under it.
- An agreed reference, as wording annexed to the agreement, with the exception noted above for regulated roles in financial services.
- The stated reason and initiator, which is the ask that costs the employer nothing and decides how your benefit claim is treated.
- Outstanding holiday, bonus and any deferred compensation, resolved explicitly rather than left to a general release.
- The scope of the release, and any confidentiality clause. ACAS names three things such a clause cannot restrict: a protected disclosure, a report of a crime to the police, and, in England and Wales, sharing information about a crime for victim support.
- The tax treatment and the timing of payment, which is an adviser's question and worth raising before the total is agreed rather than after, because a lump sum can switch off Universal Credit while New Style Jobseeker's Allowance stays claimable.
In Ireland
There is no statutory severance for a performance dismissal; negotiated exits run on ex gratia settlement payments, with tax relief that makes the same gross sum worth more when it is structured correctly, and a waiver of statutory claims needs independent advice to bind. What a claim is worth is not tariffed: compensation is capped at 104 weeks' pay and built from proven loss, which is why the job-search log is the compensation.
When. Ireland is where the timing of their ask became the case. An adjudicator found that an exit package offered three working days after a plan was activated, below contractual notice, went to the very root of the employment relationship; a lowball early offer is evidence, not merely an insult. Record the two dates. The six-month window to lodge a claim runs while you negotiate, reportedly extendable to twelve for reasonable cause — a standard the file marks as still to be verified — and resigning before the procedure completes forfeits the claim unless the facts make out a constructive dismissal, which is a heavy burden.
What to ask for. The structure of the payment for tax, on advice; the reference; and time — the file this rests on marks its figures for the tax exemption and the possible nine-week disqualification from Jobseeker's Benefit as still to be verified, so check both before relying on a number.
In Estonia
A cancellation on the capability ground — §88(1) point 2 of the Employment Contracts Act — carries no statutory severance, which is exactly why a negotiated exit attracts employers. If the cancellation is void, the law awards three months' average wage, which the dispute body may adjust. So the first ask is not money. It is the framing.
When. Before you sign anything, because the exit HR proposes, by mutual agreement, is the trap here: poolte kokkuleppel forfeits the earnings-related unemployment benefit and any remedy for a void cancellation in one signature, while an employer cancellation on point 2 preserves the benefit. And after a cancellation, thirty days from receipt to contest it at the free labour dispute committee, which decides which point applies — that is where the money question is actually fought over in Estonia, and it is free.
What to ask for. An employer cancellation stated on the capability ground, not an agreement; the redundancy month if the ending is really a redundancy; and, if a sum is on the table for a mutual agreement, one that is worth more than the benefit it costs.
In the Netherlands
The transition payment — a third of a month's salary per year of service, from the first day — is a floor, not the deal. Above it, what a weak improvement-track file is worth is the multiplier, because the employer has to win a case first and a thin improvement-track file is where courts refuse dissolution; where dissolution succeeds only on the cumulation ground the court may add up to half the payment again, and a fake or predetermined plan can ground a further award for seriously culpable employer conduct, which is loss-based rather than tariffed.
When. At the settlement agreement, which is how most Dutch cases end — and for fourteen days after signing it, twenty-one if the agreement did not tell you the right existed, since a signed agreement can be revoked without giving a reason. Practitioners say never to sign while sick, because illness triggers dismissal protection and signing it away is reported to put both the benefit and sickness pay at risk; the file marks the specifics as unverified, so put it to an adviser before signing anything during a sick leave.
What to ask for. Three things the agreement has to say come first, because the benefit dies in the drafting: the initiative stated as the employer's, a neutral non-culpable reason, and an end date a full notional notice period after signing. Then the sum above the floor; holiday pay and days; garden leave on pay; the lease car and phone wind-down; a non-compete softened or dropped; and the final settlement clause scoped.
In Spain
The anchor is a tariff: where a dismissal is ruled unfair the employer chooses between reinstatement and severance of 33 days' pay per year of service, capped at 24 months, with service before February 2012 accruing at 45, and that figure is the price list Spanish settlements are often negotiated against. The disciplinary route legally pays nothing, and one practitioner synthesis of 2024 ministry data reports it being paid anyway in large numbers — a reported figure the corpus has not been able to re-source at the ministry, and a market fact rather than a prediction.
When. After the letter, and quickly: twenty business days to lodge the conciliation filing, and the clock runs while you talk. Not in the meeting: the finiquito is signed as received and not agreed, never as a settlement of claims on the spot, because it is not the settlement.
What to ask for. Whatever the sum, the paper has to say dismissal — Spanish exits are papered as dismissals precisely so the worker keeps the benefit, and a plain mutual agreement or a resignation forfeits it and the 33-day anchor at once.
In Portugal
Compensation for the statutory unsuitability route tracks the objective-dismissal rate — base pay plus seniority payments per year of service, at a rate that has changed more than once, so it accrues in bands across those changes. The file behind this page marks the rate and the bands as needing verification before any figure is shown, so this page does not show one: ask what rate applies to each band of your service. What funds a negotiated exit is the other side's exposure: an unlawful dismissal costs 15 to 45 days per year, a minimum of three months, plus every month's wages from the dismissal to the judgment.
When. Before signing a mutual-agreement exit, because in Portugal the paperwork is the benefit: a plain revogação is voluntary and pays no unemployment benefit unless the agreement is grounded in reasons the law equates to involuntary unemployment and the employer still has room inside its rolling three-year quota. The sixty-day window to challenge a dismissal runs meanwhile.
What to ask for. The grounds clause; the Social Security form and the employer's quota declaration confirmed in writing; a clause making the employer liable to Social Security if it led you to believe the benefit conditions were met when they were not; and the question almost nobody asks — whether the quota has room.
In Germany
There is no statutory severance. What is paid is risk, priced: around half a month's salary per year of service, negotiated up to one where the employer's case is weak, and performance cases are structurally weak. The risk that prices it is yours to hold: a claim filed within three weeks of notice, reinstatement as the default remedy, and back pay for the whole litigation period if the employer loses.
When. After notice, not before. The leverage exists once a dismissal has issued and a claim is filed inside the three weeks; the classic route from there is to settle on the court record, which is the route that avoids the benefit question entirely. An Aufhebungsvertrag signed in the meeting, before any of that, collapses the anchor and presumptively causes your own unemployment — twelve weeks unpaid, plus a cut in the total entitlement — unless it sits inside the Agency's corridor: the employer had announced a dismissal on operational or person-related grounds with certainty, you were not protected from ordinary dismissal, the ordinary notice period is respected, and the severance is no more than half a gross monthly salary per year of service. The Germany page has the conditions in full, and all of them have to hold. That last one is a ceiling and not a band — older guidance set a floor of a quarter too, and the Agency's current text, dated July 2026, does not.
What to ask for. The sum against the anchor; the ground and the notice period stated so the agreement sits in the corridor if you sign one at all; and the qualified reference, the Zeugnis, with agreed wording — a statutory right with famously coded language, cheap for the employer and valuable for the search.
In France
The floor is the statutory dismissal indemnity — a quarter of a month's salary per year of service up to ten years, a third beyond, after eight months' seniority — and the indemnity in a rupture conventionnelle can never be below it. Above it, the anchor is what the employer would face if a dismissal were found without real and serious cause: the barème, brackets by seniority with ceilings rising to twenty months, on top of the indemnity, and a misclassified letter is the most common way an employer lands there.
When. The rupture conventionnelle can be opened at any point, and it is the ending designed to keep the benefit, though for contracts ending from 1 September 2026 the maximum duration of that benefit is shorter than it was. Each side has fifteen calendar days after signing to withdraw. And a dismissal of any kind keeps the benefit, with twelve months to contest it, so there is no need to accept a poor agreement to protect it.
What to ask for. The indemnity computed on the floor and the supra-legal sum anchored to the barème bracket the employer would face; the two fifteen-day clocks calendared; and the letter classified correctly, since insuffisance is not a fault and a letter that says otherwise is leverage.
If you are over forty in the United States
The waiver conditions above are age-claim conditions, and they exist because age is the one protected characteristic Congress wrote a waiver statute for. What being over forty changes about a plan and a release is the page: the twenty-one days, the seven-day revocation, and what the group disclosure has to tell you when more than one person is being let go at once. Read it before you sign anything, not after, because two of those three are periods you can only use while they are running.
If you hold a US work visa
Date outranks dollars. The grace period runs from the day after your last day of employment and severance does not extend it, so a later official termination date can be worth more than a larger lump sum; salary continuation on payroll is a grey zone only an immigration lawyer should bless. The asks that cost the employer little are written confirmation of the last day, the planned date of the petition withdrawal, and a later effective date in exchange for transition help.
Where a green-card process is running alongside the visa, the separation date is doing a second job as well. What a termination does to the queue — which stages survive it, what a withdrawn petition takes with it, and what portability preserves — is a different calculation from the grace period, and one that can be worth more than either the severance or the extra weeks.
If you hold a Canadian closed work permit
Date outranks dollars here too, for a different reason. There is no Canadian grace period, so the day the employment ends you must stop working for that employer and any other until a new permit is approved. A later last day is therefore more days you may lawfully work and more time to find an offer and file while still authorised, and it costs the employer very little. The asks are written confirmation of the exact last day, and whatever reference or employment letters the next employer's application will need, obtained while the relationship is cordial. An open permit, such as a post-graduation or spousal one, is a different situation and none of this applies to it.
What the ten answers have in common, and what they do not
What they share is the mechanism. Everywhere here, severance is priced off what a dismissal would cost the employer where you are, and the file changes the price: in Germany the sum is negotiated up where the employer's case is weak, in the Netherlands the strength of the ground is the negotiation position, in Ireland an early lowball is evidence, in the United Kingdom procedural failings support negotiation even after the plan has failed, and in the United States the release is worth what the claims it buys are worth. Everywhere, the paperwork decides the benefit, the answer is given in writing and not in the room, and signing is the act to delay.
What they do not share is where the leverage sits in time. In the United Kingdom it is often strongest at the start. In Germany it does not exist until notice has issued and a claim is filed. In Spain it runs from the letter, for twenty business days. In the Netherlands it sits at the settlement agreement, with two weeks to undo a signature; in France at any point, with fifteen days to withdraw. In Estonia it is spent the moment a mutual agreement is signed. In the United States it arrives with the document, and for a worker of 40 or over it comes with statutory days attached. In Canada it sits before the release is signed, with a national date that changes what the same offer is worth. A page that gave one answer to when would be wrong somewhere, and this one gives ten.
For the reader hoping to pass: none of this presumes an ending. The UK file this page rests on says plainly that people pass plans and stay for years. Knowing the price of an ending where you work is what lets you recognise a poor offer, and a good one, if either arrives — and asking, in writing, what the terms would be is a dated fact in your record rather than a decision.
Three situations turn a severance conversation into one to take advice on before signing rather than after: a right to be in the country that rests on the job, a regulated role, and being over forty in the United States with a release on the table. When a PIP needs a lawyer has what each one has running alongside the employment.
Every figure here is reported, not official
Fairhanded is not a law firm, and ten countries' settlement and benefit rules cannot stay current on one page for long; the chip at the top carries the date the sources behind it were last checked, and every figure attributed to a firm or an employer is reported rather than official. Before you accept, refuse or propose an ending, take the document and your dated record to an employment lawyer where you live.
Sources
What this page rests on, and when each was last read.
- 29 U.S.C. §626(f), the conditions for a valid waiver of age claimslaw.cornell.edu · read
- EEOC: understanding waivers of discrimination claims in employee severance agreementseeoc.gov · read
- Ontario: your guide to the Employment Standards Act, termination of employmentontario.ca · read
- Monaco Solicitors, on performance improvement plans and settlementmonacosolicitors.co.uk · read
- Employment Rights Act 1996 s. 203, the conditions a settlement agreement must meetlegislation.gov.uk · read
- Employment Rights Act 1996 s. 111A, confidentiality of pre-termination negotiationslegislation.gov.uk · read
- ACAS Code of Practice on settlement agreementsacas.org.uk · read
- ACAS, on making a formal settlement agreement offeracas.org.uk · read
- Hensche: Aufhebungsvertrag und Sperrzeithensche.de · read
- Bereken-transitievergoeding.nl, on the WW conditionsbereken-transitievergoeding.nl · read
- PayFit, on paro after a disciplinary dismissalpayfit.com · read
- Service-public.fr, on what changes for the rupture conventionnelle from 1 September 2026service-public.gouv.fr · read
- Segurança Social: Guia Prático Subsídio de Desempregoseg-social.pt · read
- Workplace Relations Commission, on remedies for unfair dismissalworkplacerelations.ie · read
- Ministry of Economic Affairs, on the 2026 unemployment-benefit reformmkm.ee · read
Fairhanded is not a law firm and this is not legal advice. Where your situation turns on a legal question, take it to someone qualified where you live.