UK vs Quebec Employment Law

Termination Provisions

Both Quebec and the UK have minimum statutory notice requirements for terminating employment without cause.

In Quebec, statutory notice applies once an employee has completed three months’ service. Notice increases with length of service and is not calculated strictly as one week per year, but instead follows fixed bands, with a maximum of 8 weeks’ notice for employees with ten years’ service or more.

In the UK, statutory notice is generally one week per year of employment (once an employee has been employed for two full years), capped at 12 weeks.

In the UK, it is common (but not mandatory) for employment contracts to provide for a longer contractual notice period. On termination, UK employers must give the greater of the contractual notice or statutory notice.

In Quebec, employment contracts may also specify notice entitlements, but these cannot provide less than the statutory minimums. In addition, under Quebec’s Civil Code, employees on indefinite term contracts may be entitled to “reasonable notice” in excess of statutory minimums in certain circumstances.

In both jurisdictions, no notice is required where an employee is dismissed for gross misconduct (UK) or serious fault (Quebec), provided the employer can justify the dismissal and follows a fair and proper procedure.

In Quebec, where notice is not worked and the employer provides a compensatory indemnity instead, the indemnity must generally reflect the employee’s full remuneration, including regular benefits, for the notice period. By contrast, in the UK, an employer requires a contractual right to provide payment in lieu of notice. Payment in lieu of notice is typically limited to basic salary only, unless the employment contract explicitly provides for the continuation of benefits during the notice period.

In Quebec, statutory notice entitlement is based on fixed service thresholds rather than increasing annually. Once an employee has at least three months’ service, notice is required and rises at set points, with a maximum of eight weeks, regardless of length of service. By contrast, UK statutory notice generally accrues at one week per completed year of employment once an employee has been employed for two years, subject to a 12 week cap.

Severance Pay

In Quebec, employee terminations are generally categorised as being for serious fault or without serious fault.

Unlike Quebec, UK employees do not generally benefit from unfair dismissal protection until two years’ service (although this is changing to 6 months’ service from 1 January 2027). Prior to this, employers are not required to justify the dismissal as fair, although dismissals connected to discrimination or other automatically unfair grounds remain prohibited from day one.

After this period, the following are fair reasons for dismissal: redundancy, conduct, capability, illegality or SOSR (some other substantial reason). The employer must also follow a fair process, to avoid a claim for unfair dismissal.

In Quebec, there is no separate statutory severance pay regime. Where employment is terminated without serious fault, the employer’s statutory obligation is generally limited to providing notice of termination or a compensatory indemnity.

In the UK, the only statutory sums payable to an employee on termination are those connected to redundancy: a statutory redundancy payment, which becomes payable once an employee has achieved two full years’ employment. Generally, in the UK, anything paid to the employee beyond the statutory amounts is up to the discretion of the employer.

Personal Leave and Pay Entitlements

There are also certain differences between the UK and Quebec in respect of personal leave and pay entitlements. The entitlements outlined below represent statutory minimum standards only – employers may choose to offer enhanced benefits as part of their reward and retention strategies.