Germany: Requires extensive justification for firing, works council approval, and mandates reinstatement for wrongful termination. Employer bears heavy burden of proof.
France: Must prove "real and serious cause," follow strict procedural steps, and provide mandatory tenure-based severance. Special protections for worker representatives.
Netherlands: Unique system requiring pre-approval from government agency or court before any dismissal. Heavy emphasis on severance.
Italy: Article 18 mandates justified grounds (economic or disciplinary) for firing. Court-ordered reinstatement common, especially in large companies.
Belgium: Requires detailed dismissal grounds and long notice periods up to 15 months. Mandatory outplacement services.