EOR & Compliance Digest, May 14: The UK Just Gave Employers One Week to Shape Redundancy Law

Seven days. That is how long UK employers have to formally tell the government how it should redraw collective redundancy law. The new UK collective redundancy trigger consultation closes 21 May 2026, and most HR teams have barely noticed. Meanwhile, EU employers are 80 days from a hard AI compliance deadline that could affect every hiring tool they use. Singapore is quietly closing a quota loophole that will hit companies relying on foreign worker permits in July. And Brazil’s psychosocial risk enforcement window opens in 12 days. If you manage distributed teams across any of these regions, act now.

UK Collective Redundancy Trigger Consultation Closes in 7 Days

What Changed

The UK government launched a consultation in February on how to set a new organisation-wide threshold for collective redundancy obligations under the Employment Rights Act 2025. The consultation closes on 21 May 2026. (Source: UK Government)

Under current rules, collective consultation duties apply when an employer proposes 20 or more redundancies at a single establishment within 90 days. However, the Employment Rights Act 2025 replaces that site-based test with an organisation-wide headcount. The government is consulting on a trigger range of 250 to 1,000 dismissals across the whole organisation. Tiered models based on employer size are also on the table. The intended go-live date for the new UK collective redundancy trigger is 2027, with the exact date still to be confirmed. (Source: Pinsent Masons)

Why It Matters for Distributed Teams

The current site-based test was straightforward to work around. A company with 10 UK offices could run 15 redundancies per site and avoid collective consultation entirely. The organisation-wide UK collective redundancy trigger closes that gap. As a result, multi-site and remote-first employers who planned redundancies at the establishment level will need to redesign their processes.

For EOR providers and HR teams managing distributed UK employees, the change is significant. If you have UK headcount spread across remote workers, branch offices, and co-working spaces, today every location counts separately. Under the new rules, all of those employees pool into a single organisation-wide count. The consequence: collective consultation, the 45-day minimum notice period, and Insolvency Service notifications could apply much earlier than expected.

Moreover, the penalty for skipping consultation already increased from 6 April 2026. The maximum protective award for failure to inform and consult in collective redundancy rose from 90 days to 180 days’ pay. Any restructuring that bypasses consultation now carries double the previous financial exposure.

Collective Redundancy Action Plan: Before May 21

First, review the consultation document on gov.uk and decide whether to submit a response. You have until 21 May. If you are a large employer or you manage EOR headcount in the UK, your response could directly influence the threshold written into law. Second, map your current UK headcount across all locations. You need a clean picture of where your people sit before the organisation-wide UK collective redundancy trigger becomes law. Third, audit your existing UK employment law obligations. The April 2026 changes to SSP, paternity leave, and the protective award are already live, and some employers have not updated their processes.

EU AI Act August 2 Deadline: 80 Days for HR Tech Teams

The EU AI Act’s high-risk system obligations apply from 2 August 2026. That is 80 days away. Under Annex III of the Act, AI systems used in recruitment, candidate selection, performance evaluation, and worker monitoring are classified as high-risk. So are tools used in task allocation or termination decisions. Fines for non-compliance can reach €15 million or 3% of global annual turnover, whichever is higher. (Source: Crowell & Moring)

There is a complication, however. On 7 May 2026, a political agreement was reached on the Digital Omnibus, which proposes to defer the high-risk obligations from August 2, 2026, to December 2, 2027. But the Omnibus is not yet formally adopted. Because of this, the August 2 deadline remains legally binding under existing law. Organisations that pause compliance preparation while waiting for the Omnibus to pass are taking a real legal risk. (Source: DLA Piper)

For EU-based employers, the practical path is clear: keep your compliance preparation running. If you deploy AI tools for screening, scoring, or performance reviews, you need documented risk assessments, bias testing, and human oversight in place before August 2. In Germany specifically, an additional obligation applies. Employers must inform workers’ representatives before deploying high-risk AI systems at the workplace. Therefore, if your company has a works council, you need to brief them before the August 2 deadline. See your Germany employment law compliance checklist if you hire there.

Singapore Raises the Salary Bar for Foreign Worker Quotas

From 1 July 2026, Singapore’s Local Qualifying Salary rises from S$1,600 to S$1,800 per month. That threshold determines how local employees count toward S Pass and Work Permit quota calculations. (Source: Mothership SG / Source: Singapore MOM)

Here is the mechanism: each local employee earning at least S$1,800 counts as 1.0 in your quota headcount. A local employee earning between S$900 and S$1,799 counts as only 0.5. Below S$900, they count as zero. Because your S Pass and Work Permit allocation is a fixed ratio of that local headcount, fewer qualifying local employees means fewer available foreign worker slots. For companies that rely on S Pass holders in operations, tech support, or manufacturing, this matters immediately. Specifically, you could lose foreign worker slots if you don’t raise local salaries first.

The Singapore government is providing relief through the Progressive Wage Credit Scheme, which subsidises wage increases for lower-wage Singaporean employees through 2028. However, the subsidy does not automatically lift all affected employees above S$1,800. You need to run the numbers for your specific workforce before July 1. Check your Singapore salary structure and compliance guide for current benchmarks.

Quick Hits

• Germany Works Council elections close 31 May. German companies with existing works councils must complete their regular four-year elections by 31 May 2026. Employers must remain strictly neutral and cannot support or pressure individual candidates. Missing the window triggers extraordinary election procedures, which delay any decisions requiring works council consent. (Source: Mayer Brown)
• Brazil NR-1 enforcement begins 26 May. Workplace psychosocial risk assessments become enforceable in 12 days. Every employer in Brazil must have identified psychosocial risks, documented them in the Occupational Risk Management Program (PGR), and implemented mitigation measures. Inspectors will prioritise banking, healthcare, and telemarketing sectors in the initial enforcement wave. (Source: Fisher Phillips)

Action Items This Week

If you have UK headcount: Submit a response to the UK collective redundancy trigger consultation by 21 May 2026. Map your UK employees across all locations now. Confirm your payroll provider has applied the updated protective award cap of 180 days from 6 April. Review the full UK Employment Rights Act 2025 changes if you have not yet done so.

If you deploy AI hiring or performance tools in the EU: Confirm whether your vendors have completed risk assessments and bias testing under EU AI Act Annex III. Brief your works council in Germany before August 2. Do not rely on the Omnibus deferral until it is formally enacted and published in the Official Journal.

If you hire via S Pass or Work Permits in Singapore: Run your headcount through the new LQS formula before 1 July. Any local employee below S$1,800 reduces your foreign worker quota. Coordinate with payroll on wage adjustments and verify PWCS subsidy eligibility to offset the cost increase.

If you have employees in Brazil: Confirm your PGR includes a psychosocial risk section before 26 May. Enforcement starts in 12 days. Any registered workplace in Brazil is in scope, including EOR-managed employees and employees of local entities.

Managing compliance deadlines across multiple jurisdictions is difficult when the rules shift constantly. Asanify’s Global HRMS tracks statutory changes across 100+ countries and integrates payroll for distributed teams. If any of these updates have prompted a closer look at your global hiring setup, it is worth a review.

Frequently Asked Questions

What is a collective redundancy trigger and why does the UK change matter for international employers?

A collective redundancy trigger is the threshold at which an employer must begin formal consultation before making employees redundant. The UK is shifting from a site-based test of 20 dismissals at one location to an organisation-wide headcount test. For international employers with distributed UK teams across remote workers and multiple offices, this means even modest restructuring plans could trigger the full consultation process and 45-day notice requirements for the first time.

Do EU AI Act obligations apply to non-EU companies hiring in EU countries?

Yes. The EU AI Act applies to any entity deploying AI systems that affect people located in the EU, regardless of where the company is headquartered. If you use an AI tool for hiring, performance reviews, or worker monitoring that operates on EU-based employees, you fall within scope. Non-EU companies with no EU legal entity must appoint an authorised representative inside the EU.

How does Singapore’s LQS increase affect EOR-managed employees?

The LQS change applies to the quota calculation for the entire workforce operating under the same employer account. If local Singaporean employees managed by an EOR fall below S$1,800, those employees count as only 0.5 toward the quota rather than 1.0. This reduces the total number of foreign worker slots available to the company. Confirm the details and quota projections with your EOR provider before July 1.

What happens if a German employer misses the Works Council election window?

Missing the regular election window from March 1 to May 31 does not end the obligation. An extraordinary election must be organised outside the regular cycle. Any decisions requiring works council consent, including technology changes, restructuring plans, or working condition adjustments, can be contested or delayed until a properly elected council is in place.

What does a psychosocial risk assessment in Brazil actually require?

Under the updated NR-1 standard, every Brazilian employer must identify psychosocial hazards such as excessive workload, workplace harassment, lack of autonomy, and insufficient recognition. These must be documented inside the Programa de Gerenciamento de Riscos alongside a prevention and mitigation plan. The obligation applies to all registered workplaces in Brazil, regardless of headcount, including EOR-managed employees and employees of local entities.

Not to be considered as tax, legal, financial or HR advice. Regulations change over time so please consult a lawyer, accountant  or Labour Law  expert for specific guidance.