HR on both sides of the Atlantic.
Someone who's actually worked there.

The US rules don't transfer.

If your business is based in the US but you have staff working in the UK, you're operating under two very different employment frameworks simultaneously. UK employment law has no concept of at-will employment. Every employee has statutory rights from day one — minimum notice periods, statutory sick pay, and protection from unfair treatment. Get it wrong and you're exposed to employment tribunal claims.

The Employment Rights Act 2025 is the most significant reform to UK employment law in a generation. It's phasing in across 2026 and 2027 and has already started. If you haven't reviewed your UK employment contracts, policies, and HR practices against the new Act, now is the time.

• Statutory Sick Pay payable from day one — no lower earnings limit or waiting period
• Day-one rights to paternity leave and unpaid parental leave
• Maximum protective award for collective redundancy failures doubled to 180 days' pay
• Strengthened whistleblowing protections
• Significantly expanded employer duties to prevent sexual harassment
• New employer liability for third-party harassment of staff
• Simplified trade union recognition — relevant even without prior union activity
• Employment tribunal time limits extending from three to six months from October 2026

From January 2027, the qualifying period for unfair dismissal claims reduces from two years to six months — meaning anyone you hire from around June 2026 onwards will qualify for unfair dismissal protection far sooner than you might expect.

I can help you understand what applies to your business, what needs updating, and what good looks like for a US employer with UK staff — without the legal fees of instructing a UK law firm for every question.

The US catches a lot of UK businesses off guard.

It looks familiar — same language, broadly similar business culture — and then you discover that hiring your first American employee involves navigating federal law, state law, benefits expectations that are nothing like the UK, and worker classification rules that carry serious penalties if you get them wrong.

A few things UK companies commonly underestimate:

• At-will employment is real — and complicated.Most US employees can be terminated at any time for any lawful reason, but the exceptions and the documentation requirements matter enormously. Getting terminations wrong is expensive.
• State law varies significantly.Employment obligations in California, New York, or Illinois are materially different from North Carolina or Texas. Where your employees are located determines which rules apply — and "we'll just use a standard US offer letter" is not a compliance strategy.
• Benefits are not statutory.Unlike the UK, there's no equivalent of NHS healthcare or auto-enrolment pensions. US employees expect employer-sponsored health insurance, and your ability to compete for talent depends heavily on your benefits package.
• Worker classification is high-stakes.Misclassifying an employee as an independent contractor carries back taxes, penalties, and potential litigation. The rules are more complex than most UK businesses realise.
• Documentation protects you.The US is a more litigious employment environment than the UK. Proper offer letters, handbook policies, and HR records are not administrative overhead — they're your legal protection.

I can help you build your US people function properly from the start — the right documentation, the right policies, and the right approach for the states where your team is based.

What this looks like in practice.

Every engagement starts with a discovery call — 30 minutes to understand your situation, your people, and what you actually need. From there, we agree a scope that works for you: a one-off review, a defined project, or ongoing fractional support as your business navigates both markets.

There's no retainer you're locked into before you know what you're getting. I do the work.