Global Labor Law Weekly: UK, Vietnam, US Updates

September 7 – 13, 2026: global employment rules entered their autumn adjustment window. The UK's Employment Rights Act 2025 is closing in on three major October changes; Vietnam began fining employers that fail to report foreign workers and brought its forced-labour import ban into force; Florida's minimum wage will rise to $15.00/hour on September 30, while Maryland set an $18 floor for government contract workers; and EU member states are in the final stretch of transposing the Pay Transparency Directive. Here is what changed, when it takes effect, and what cross-border employers should do.

1. Europe: Three UK Changes Are Weeks Away

1.1 UK: Tribunal time limits double from 3 to 6 months (effective 1 Oct 2026)

According to Wansbroughs' September 2026 employment law update, from 1 October 2026 the time limit for bringing most Employment Tribunal claims rises from three months to six months, covering unfair dismissal, discrimination, whistleblowing detriment and unlawful deductions from wages. The new limit generally applies to dismissals, acts or omissions occurring on or after 1 October 2026; earlier events remain subject to the three-month rule, and continuing-conduct cases need case-by-case assessment. ACAS Early Conciliation still affects time-limit calculations. Employers should extend evidence and record retention, preserve emails and messages quickly, document decisions, and review dispute-reporting and insurer-notification procedures. The government's Employment Rights Act implementation timeline confirms the sequencing.

1.2 UK: Sexual harassment duty upgraded to "all reasonable steps" (effective 30 Oct 2026)

The preventive duty under the Equality Act 2010 is raised from "reasonable steps" to "all reasonable steps" to prevent sexual harassment of employees. What counts as "all reasonable steps" depends on the organisation's size, resources, working environment and specific risks. Regulators are explicit that a written policy alone is not compliance: employers need risk assessments, anti-harassment and grievance/whistleblowing policies, accessible reporting routes, refreshed practical training, prompt and impartial investigations, disciplinary and remedial action, and monitoring for retaliation — all with retained evidence.

1.3 UK: Third-party harassment liability (October 2026, subject to commencement)

Employers will face liability where a third party — customers, clients, suppliers, contractors, patients or visitors — harasses a worker in the course of employment and the employer failed to take all reasonable steps to prevent it. Unlike the previous regime, a single incident may be sufficient. Practical measures include conduct standards, staff training, accessible reporting, authority for managers to intervene, contractual protections and documented responses (warning or removing the third party, ending the interaction, banning the individual or reporting to police).

1.4 UK: Right to Work checks extended to labour supply chains (effective 1 Oct 2026)

Under the Border Security Act 2025, from 1 October 2026 immigration compliance obligations extend beyond direct employers into labour supply chains, subcontracting arrangements and certain platform-based business models, with civil penalty exposure for non-compliance (source: WFW — Right to work checks from 1 October 2026).

1.5 EU: Pay Transparency Directive transposition enters the final stretch

Member State transposition of the EU Pay Transparency Directive (Directive (EU) 2023/970) is nearing completion. Trusaic published an update to its Member State Transposition Monitor on 8 September, and Euronews reported the same day that pay-range disclosure in job adverts remains uneven, underlining the gap between legislative intent and practice. For employers, job-advert pay ranges, internal pay structures and gender pay-gap reporting become hard Q4 2026 deliverables — HR systems and compensation architecture should be scheduled now.

1.6 France: 2027 budget signals employer relief

France's Prime Minister said on 9 September that the 2027 budget will reduce the corporate tax surcharge and ease employee equity/buyout arrangements — a medium-term signal for employers operating in France or using equity incentives.

2. Asia Pacific

2.1 Vietnam: fines for foreign-worker reporting violations (effective 10 Sept 2026)

From 10 September 2026, Vietnam began fining employers that fail to meet their foreign-worker reporting obligations. This continues Vietnam's tightening of expatriate workforce management, covering work permits, labour-demand declarations and headcount-change notifications. The penalty falls on the employer, not the foreign employee.

2.2 Vietnam: forced-labour import ban in force (from 8 Sept 2026)

Vietnam has banned imports of goods produced with forced labour under a new decree, confirmed this week as in force (source: Vietnam Government Portal). Companies with Vietnamese supply chains exporting to Europe and the US should audit supplier labour compliance and traceability documentation, so that upstream labour issues do not become import barriers. Vietnam Briefing also analysed Resolution 19-NQ/TW's implications for FDI strategy and Decree 169 customs penalties.

2.3 China: minimum wage guidance and executive IIT planning updated

China Briefing updated its Minimum Wages in China guide on 7 September (provincial rates, application scope, adjustment cadence) and on 8 September published guidance on structuring executive compensation before signing, focused on individual income tax (IIT) exposure. August tax commentary also flagged the expiry of foreign dividend relief and tighter VAT compliance, which indirectly affects expatriate compensation and assignment cost calculations.

2.4 India: labour codes rollout still uneven

Rollout of India's new labour codes remains patchy — only four states had fully operationalised the central codes as of June, with detailed rules still awaited. Take-home pay is the key employer concern: one estimate suggests an employee on roughly INR 1.5 million CTC could see take-home pay fall by about INR 8,000, driven by PF/social-security contribution base changes. On the judicial side, the Supreme Court on 20 August scrapped the worker-friendly 1978 "industry" precedent to align with the new code definitions.

2.5 Japan: overtime guidance and minimum wage both shifting

Japan's labour ministry has ended its blanket 45-hour overtime guidance, moving to a more case-by-case approach that requires employers to revisit 36 Agreements and overtime controls. At the same time, minimum wage increases have slowed under the current government, affecting labour-cost budgeting and staffing pricing; tighter rules for foreign residents add compliance burden to talent acquisition and visa renewals.

3. Middle East & Africa

3.1 UAE: labour law violations down 15% in H1 2026

The UAE Ministry of Human Resources and Emiratisation reported that the number of private-sector establishments violating labour law fell 15% year on year in H1 2026, though illegal hiring and unpaid salaries remain the top offences. Overall compliance is improving, but sourcing practices and wage payment stay under scrutiny — supplier and intra-group compliance audits remain worthwhile.

3.2 Saudi Arabia: major change to job application rules

On 8 September Saudi Arabia made a major change to job application and recruitment rules, affecting how employers post roles and how candidates apply — employers hiring in the Kingdom should update recruitment SOPs and record-keeping. Enforcement also intensified: Saudi Arabia deported 12,057 people after a week-long security crackdown.

3.3 South Africa: workplace inspections stepped up

South Africa's Department of Employment and Labour announced on 9 September that it is intensifying workplace inspections in Mpumalanga, focusing on wages, working time and employment-contract compliance. Minimum wage and registration duties for domestic workers were also widely flagged by local media.

4. Americas

4.1 US: the autumn minimum wage window opens

Florida's minimum wage rises from $14.00 to $15.00/hour on 30 September 2026 — the final step in a multi-year phase-in (source: Ballotpedia — Minimum wage increases in 2026) — requiring payroll and tipped-wage updates. Minnesota's nursing-home minimum wage standards took effect on 10 September, and Maryland's Governor announced on 7 September an $18 minimum wage for BWI airport direct contract workers plus emergency legislation to reform the Secure Maryland Wage Act. Government contracts and outsourced labour are becoming the new lever for minimum wage policy.

4.2 US: states tighten pay transparency and personnel-record rules

Connecticut expanded pay transparency requirements, obliging employers to post credible wage ranges, alongside updated pay, accommodation and AI-employment obligations. New York State now requires employers to provide employees with access to personnel records, with the Governor signalling amendments may be needed — employers should build response timelines and record-management workflows. California is in its legislative wrap-up, with wage-and-hour settlements continuing to flag risk, and the US DOL issued a Field Assistance Bulletin on mental-health-parity enforcement. Several states are also moving to backstop labour protections for gig workers such as Uber drivers and cannabis workers.

4.3 Canada and Mexico

In Canada, Dentons published Doing business in Canada: labour and employment law considerations on 11 September, summarising federal and provincial requirements for companies setting up there. In Mexico, analysis continued on the progressive impact of NOM-035 (psychosocial risk prevention) on labour reform, keeping mental-health risk management on the compliance agenda.

5. Employee Tax, Social Security & Pay Transparency: Rebuild the After-Tax Cost Base

Tax and social-security signals clustered this week, and they point in one direction: the after-tax view of total employment cost (CTC) needs to be rebuilt.

US: debate over raising the Social Security wage cap intensified, while research highlighted the contribution gap created by misclassification and pass-through entities — directly relevant to companies using contractors and EOR structures. Alabama confirmed that employers are no longer required to withhold state income tax on nonresident wages earned for work performed outside the state. Proposed rules also clarified employer contributions to "Trump Accounts", and interim guidance was issued on the excess executive-compensation excise tax.

Europe: France plans a lower corporate tax surcharge and easier employee equity/buyouts; the EU pay transparency transposition monitor was updated, making pay ranges and gender pay-gap reporting hard Q4 deliverables.

Asia Pacific: China updated executive IIT planning and flagged the expiry of foreign dividend relief and tighter VAT compliance; India's PF/social-security base changes directly affect take-home pay and employer cost.

6. Trends & What to Watch Next Week

Trend 1 — the compliance calendar clusters in October. The UK's 1 October changes (time limits, right-to-work extension) and 30 October "all reasonable steps" duty stack with US wage and transparency rules around 30 September / October, so policies, systems and training must land in late September.

Trend 2 — pay transparency moves from legislation to enforcement and reality. EU transposition is wrapping up, job-advert disclosure remains uneven, and Connecticut expands transparency from October: "are the pay ranges credible?" is becoming an auditable standard.

Trend 3 — compliance responsibility keeps spilling into supply chains and platforms. Vietnam's forced-labour import ban, the UK's extension into labour supply chains and platform models, and US state moves to backstop gig workers all shift responsibility from the direct employer to the wider employment ecosystem.

Trend 4 — tax and social security are Q4's second cost front. Social Security caps and misclassification in the US, Alabama's withholding change, French corporate tax relief, Indian PF bases and Chinese executive IIT planning all point to rebuilding the after-tax cost base.

Watch next week (14–20 September 2026): UK implementation guidance and ACAS materials for the October changes; EU member-state transposition progress (Spain, Portugal, Czechia and others); Vietnam's first enforcement cases after foreign-worker reporting fines began; payroll system updates ahead of US state minimum wages effective 30 September / 1 October; and employer readiness for Connecticut's expanded pay transparency. For global tracking, see Mercer — Global Legislative Update and Fisher Phillips — Employer Checklist for September 2026.

* This article is for general information only and does not constitute legal advice. Please consult local counsel for specific situations.