The words in the room

The same event, under different names

What you are doing has a different word in almost every English-speaking jurisdiction, and the word usually carries a different legal test with it. If you are searching for guidance and finding nothing useful, this is often why: you are using your own country's word.

Redundancy — United Kingdom, Ireland, Australia, New Zealand

The Fair Work Ombudsman in Australia puts the common thread most plainly: "Redundancy is when a business no longer needs an employee's job to be done by anyone." Employment New Zealand describes it as where employment "is terminated because their position has become surplus to the requirements of the business". Same word, different statutes: the Fair Work Act 2009 in Australia, the Protection of Employment Acts 1977 to 2024 in Ireland.

Sources: Fair Work Ombudsman, Redundancy and Employment New Zealand, Redundancy. Checked 18 September 2026.

Layoff, mass layoff and plant closing — United States

"Layoff" in American usage covers what the rest of the English-speaking world calls redundancy, and it is not temporary. The federal WARN Act sets defined events: a covered mass layoff occurs, per the Department of Labor, "when 50 to 499 employees are affected during any 30-day period at a single employment site... if these employees represent at least 33 percent of the employer's workforce where the layoff will occur, and the layoff results in an employment loss for more than six months", with the 33 per cent test dropping away at 500 or more. WARN "generally covers employers with 100 or more employees" and requires "notification 60 calendar days in advance of plant closings and mass layoffs". States add their own, often stricter, versions.

Source: US Department of Labor, Notices for Plant Closings and Mass Layoffs. Checked 18 September 2026.

Reduction in force, or RIF — United States corporate usage

Internal company language rather than a statutory term, used for the exercise as a whole. It has no definition in the WARN Act and confers nothing; whether a given RIF is a covered event under WARN depends on the numbers, not on what it is called internally.

Lay-off and group termination — Canada

Canada distinguishes them. A temporary lay-off is where an employer lays somebody off "for a short term with the intention to recall the employee back to work", and it becomes a termination when those conditions no longer apply. A group termination, under the federal Canada Labour Code, "is the termination of employment of 50 or more employees working at a single industrial establishment" either on the same date or within any four-week period, and requires written notice to the Labour Program's Head of Compliance and Enforcement "at least 16 weeks before the termination of employment is to take effect". Provincially regulated employers follow their own province's rules instead.

Source: Government of Canada, Termination, layoff or dismissal. Checked 18 September 2026.

Retrenchment — South Africa

The term for dismissal based on the employer's operational requirements, under sections 16, 189 and 189A of the Labour Relations Act. The Department of Employment and Labour states that "a company may only retrench people as a last resort", and that consultation must seek consensus on avoiding retrenchments, reducing the number, changing the timing, softening the effect, the severance package and how those affected were chosen. Section 189A brings in additional requirements by size: for an employer of 50 to 200 staff it applies at 10 or more; 201 to 300 at 20 or more; and so on to 50 or more in an employer of 501 or more.

Source: South African Department of Employment and Labour, Retrenchment and your legal rights. Checked 18 September 2026.

Retrenchment — Singapore

The same word, an entirely separate system. The Ministry of Manpower requires an employer registered in Singapore with at least 10 employees to notify the Ministry of any retrenchment, within five working days of notifying the affected employee.

Source: Singapore Ministry of Manpower, Mandatory Retrenchment Notifications. Checked 18 September 2026.

Collective redundancy — Ireland

Ireland sets its threshold by sliding scale over any 30 consecutive days: 5 or more where 21 to 49 are normally employed; 10 or more where 50 to 99; 10 per cent or more where 100 to 299; and 30 or more where 300 or more. The Workplace Relations Commission states that consultation must run "at least 30 days" and begin "at the earliest opportunity and at least 30 days before the first notice of dismissal is given", that no notice of redundancy may be issued during that process, and that dismissals cannot take effect until at least 30 days after the Minister has been notified.

Source: Workplace Relations Commission, Collective Redundancies. Checked 18 September 2026.

The notification threshold — Australia

Included because it is the lowest of the ones on this page and therefore the easiest to cross without noticing. The Fair Work Ombudsman states that an employer considering making 15 or more employees redundant must give Services Australia written notification before the employees are made redundant, setting out the reasons, the number and categories of employees likely to be affected, and the timing.

Source: Fair Work Ombudsman, Redundancy. Checked 18 September 2026.

Despido colectivo — Spain

Spain's term, set out in full in the Spanish section below, with a threshold that begins at ten workers rather than twenty and a statutory compensation formula that has no British equivalent.

Every entry above is the name of an event and, where the authority states one, its trigger. None of it tells you what applies to your business, and the differences between these systems are large enough that a rule remembered from one country is actively misleading in another. That is a question for an employment lawyer admitted where your people are employed.