ELIAnAmerican: European Software Industry Employment Contracts
February 24, 2021 9:35 AM Subscribe
I am an American software engineer actively applying for employment in the UK, Ireland, the Netherlands, and Germany. Years of work experience in the US (specifically California) have given me a decent layman's understanding of the expectations for software industry employment agreements there. It looks like employment agreements in my European target countries are structured pretty differently, e.g., with probationary periods. What should I keep in mind when assessing these contracts? What should I watch out for? What country-specific issues should I be aware of?
Probationary periods are normal across all professions in the UK for permanent roles. This is because we don't have at-will employment, and usually once you have passed your probation period your employer will use more due process if they want to get rid of you (although I think that may not actually legally enforceable unless you have been working for that employer for 2 years or more).
Similarly, most employment contracts have longer notice periods than would be normal in the US, typically 1 month but sometimes 3 months. These can sometimes/often be negotiated when you resign, and so I think I'd recommend accepting them as standard rather then trying to push against them.
Sick pay here can vary quite a bit. There is a statutory minimum but many white collar employers are much more generous than that. Similarly, there are rules about minimum pension (retirement) contributions, although the employee can opt out. Doing some reading around the specifics in a scheme you're offered is probably helpful.
posted by plonkee at 2:32 PM on February 24, 2021
Similarly, most employment contracts have longer notice periods than would be normal in the US, typically 1 month but sometimes 3 months. These can sometimes/often be negotiated when you resign, and so I think I'd recommend accepting them as standard rather then trying to push against them.
Sick pay here can vary quite a bit. There is a statutory minimum but many white collar employers are much more generous than that. Similarly, there are rules about minimum pension (retirement) contributions, although the employee can opt out. Doing some reading around the specifics in a scheme you're offered is probably helpful.
posted by plonkee at 2:32 PM on February 24, 2021
Best answer: I'm an American system engineer living in Germany, working for the German division of a medium sized US company for the last 2.5 years. Previously, I worked for the American division for 3 years. Coming from the Bay Area, there were a few things in my work contract that had be nervous, but turned out to be no issue. In general, it's pretty similar to the employment agreements I've signed in the US. I have an unlimited contract, so there's no end date.
Some of the really important things:
Getting fired is hard, outside the probation period, unless you are violating company policy.
Probationary period: 6 months I think that might be standard, but each company may be different. You're SOL during this period if you get let go. Current law (in Bavaria, but it may be a Federal law) requires a 2 weeks notice period, in writing. This applies to both you and the company.
Unlike the US, your health insurance coverage begins immediately.
-
Mandatory notice period: often tied to your length of employment:
- First year: 6 weeks
- over 1 year: 2 months
- over 2 years: 3 months
- over 3 years: 4 months
At my company, if someone is let go, they'll often be given some period to complete any open work and do handover. You will then take any of your remaining vacation time. Then, they will pay out the remainder of time for the notice period. Some employers will make you come to the office every day for that final 4 months. It's up to the company.
This notice period applies to both you and the employer. If you up and quit, the employer can legally demand compensation for the notice period. Often, you'll just begin working. It's not unheard of to be offered a job, and then start 4 months later. We interviewed and hired someone in December. They start next week, because they had to finish our the notice requirements at their current job.
-
Salary: generally paid monthly. Some companies split your pay into 13 payments, and give you the "extra" at the end of the year.
-
Health: There's no real cap on sick days, but you need a notice from a doctor. If you are sick for more than 2 weeks, the company has. right to demand a medical examination, at their cost. You also have the right to take a sabbatical for mental or physical fatigue at a "health spa". I think this can be upwards of 6 weeks. The health spa is covered by insurance.
-
Vacation time: minimum 24 days that do not accrue year to year. If you haven't taken any vacation during the year, expect to get pushed by management to take it. You typically have until March of the following year to take the time. My company gives 29 days. I'm a workaholic, so while this sounds amazing, it's actually pretty tough.
-
Bonus:
Health insurance (Krankenkasse): the premium is percentage-based. I'm with Techniker Krankenkasse. Their rate is currently 15.8% of gross salary: 14.6% is the general contribution, and 1.2% is the supplementary employee contribution. I think the max contribution is somewhere around €1000.month. You and the company will split the cost of the general contribution 50/50. I'm not sure if this applies to private insurance companies. I opted for the public insurance and have been quite happy with it. If you are married, your partner is covered 100% for no extra cost.
I hope this is helpful. While I pay more for taxes and health insurance premiums than I did in the US, it's all completely worth it.
If you like, I can send you a redacted version of my current contract, which is in English and German
posted by zerokey at 11:38 PM on February 24, 2021
Some of the really important things:
Getting fired is hard, outside the probation period, unless you are violating company policy.
Probationary period: 6 months I think that might be standard, but each company may be different. You're SOL during this period if you get let go. Current law (in Bavaria, but it may be a Federal law) requires a 2 weeks notice period, in writing. This applies to both you and the company.
Unlike the US, your health insurance coverage begins immediately.
-
Mandatory notice period: often tied to your length of employment:
- First year: 6 weeks
- over 1 year: 2 months
- over 2 years: 3 months
- over 3 years: 4 months
At my company, if someone is let go, they'll often be given some period to complete any open work and do handover. You will then take any of your remaining vacation time. Then, they will pay out the remainder of time for the notice period. Some employers will make you come to the office every day for that final 4 months. It's up to the company.
This notice period applies to both you and the employer. If you up and quit, the employer can legally demand compensation for the notice period. Often, you'll just begin working. It's not unheard of to be offered a job, and then start 4 months later. We interviewed and hired someone in December. They start next week, because they had to finish our the notice requirements at their current job.
-
Salary: generally paid monthly. Some companies split your pay into 13 payments, and give you the "extra" at the end of the year.
-
Health: There's no real cap on sick days, but you need a notice from a doctor. If you are sick for more than 2 weeks, the company has. right to demand a medical examination, at their cost. You also have the right to take a sabbatical for mental or physical fatigue at a "health spa". I think this can be upwards of 6 weeks. The health spa is covered by insurance.
-
Vacation time: minimum 24 days that do not accrue year to year. If you haven't taken any vacation during the year, expect to get pushed by management to take it. You typically have until March of the following year to take the time. My company gives 29 days. I'm a workaholic, so while this sounds amazing, it's actually pretty tough.
-
Bonus:
Health insurance (Krankenkasse): the premium is percentage-based. I'm with Techniker Krankenkasse. Their rate is currently 15.8% of gross salary: 14.6% is the general contribution, and 1.2% is the supplementary employee contribution. I think the max contribution is somewhere around €1000.month. You and the company will split the cost of the general contribution 50/50. I'm not sure if this applies to private insurance companies. I opted for the public insurance and have been quite happy with it. If you are married, your partner is covered 100% for no extra cost.
I hope this is helpful. While I pay more for taxes and health insurance premiums than I did in the US, it's all completely worth it.
If you like, I can send you a redacted version of my current contract, which is in English and German
posted by zerokey at 11:38 PM on February 24, 2021
I would add that Germany has a lot of employment laws that tend to protect the employee. We get regular emails for example reminding us that we *can’t* work more than so many hours per day, week, month, or that no matter what the project situation is, we aren’t allowed work on Sundays. And yes, management and HR are pretty insistent that holidays are taken.
I’d agree that private health insurance isn’t necessary in Germany, however, it is advisable in Ireland. (It’s not as bad as the US - you’re not going to be bankrupted, but the public health service is not that great there.)
It will be difficult to compare any offers between countries - and possibly even between cities within a country. Cost of living is very important. (Housing costs in Ireland are very high, for example.) Taxes and insurance will also be different, as well as what you get for your taxes.
It’s also important to be aware that unless you already have some sort of status that allows you residence in the EU and/or UK, it will require just that little bit more effort for a company to take you rather than an EU and/or UK citizen.
posted by scorbet at 2:52 PM on February 25, 2021
I’d agree that private health insurance isn’t necessary in Germany, however, it is advisable in Ireland. (It’s not as bad as the US - you’re not going to be bankrupted, but the public health service is not that great there.)
It will be difficult to compare any offers between countries - and possibly even between cities within a country. Cost of living is very important. (Housing costs in Ireland are very high, for example.) Taxes and insurance will also be different, as well as what you get for your taxes.
It’s also important to be aware that unless you already have some sort of status that allows you residence in the EU and/or UK, it will require just that little bit more effort for a company to take you rather than an EU and/or UK citizen.
posted by scorbet at 2:52 PM on February 25, 2021
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I also once got a clause removed saying that I wouldn't get sick pay above the statutory minimum during the probationary period.
posted by quacks like a duck at 12:20 PM on February 24, 2021