# Termination With Notice in Singapore vs Dismissal Rules in Italy

> In Singapore you can end employment with notice and no reason. In Italy, after probation, every dismissal needs a justified reason. What changes.

For a Singapore company, ending an employment relationship is usually a contract question: give the notice in the contract, or pay salary in lieu. Italy does not work that way. This is the biggest legal difference a Singapore team will meet when it hires in Italy.

## Singapore: notice without a reason

Under the Employment Act, either party can end a contract of service by giving notice in writing. The notice period is whatever the contract says. If the contract is silent, the statutory default applies:

| Length of service | Default notice |
|---|---|
| Less than 26 weeks | 1 day |
| 26 weeks to less than 2 years | 1 week |
| 2 years to less than 5 years | 2 weeks |
| 5 years or more | 4 weeks |

Salary in lieu of notice is an alternative. MOM states plainly that the employer is not required to give a reason for termination with notice.

The limit is wrongful dismissal. Under the Tripartite Guidelines on Wrongful Dismissal, a dismissal is wrongful if it is discriminatory, made to deprive the employee of benefits, made in retaliation for exercising a right, or based on misconduct or poor performance the employer cannot prove. Claims go to the Tripartite Alliance for Dispute Management (TADM) within one month of the last day of work, and then to the Employment Claims Tribunals. The Workplace Fairness Act will add further protection against discrimination when it takes effect <!-- review: confirm commencement date, reported as by end-2027 -->.

But the default remains: with notice, no reason is needed.

## Italy: every dismissal needs a reason

Italy has had the opposite default since Law 604/1966. After the probation period, an employer can dismiss only for:

- **just cause** (giusta causa, art. 2119 Civil Code): misconduct so serious that the relationship cannot continue even for the notice period. No notice is due.
- **justified subjective reason** (giustificato motivo soggettivo): a significant breach of the employee's obligations, less serious than just cause. Notice is due.
- **justified objective reason** (giustificato motivo oggettivo): reasons tied to the business, such as the closure of a role or reorganisation. Notice is due. The employer must show the reason is real and, under case law, generally that the employee could not be moved to another role.

Dismissal must be in writing and state the reasons. Notice periods (art. 2118 Civil Code) are set by the CCNL by level and seniority, and pay in lieu of notice is possible.

Disciplinary dismissals must follow the procedure in art. 7 of the Workers' Statute (Law 300/1970): written charges, time for the employee to respond, and a hearing if requested, before any decision.

Poor performance alone is a difficult ground. It can support a dismissal only when it reflects a clear and documented failure, usually through the disciplinary route.

## What happens if the dismissal is unjustified

For employees hired from 7 March 2015, the Jobs Act (Legislative Decree 23/2015) sets the remedies. In most cases of unjustified dismissal, the remedy is compensation measured in months of pay, based on seniority, within a minimum and maximum. Reinstatement remains for discriminatory, void or oral dismissals and some disciplinary cases where the alleged fact did not exist. For employers with more than 15 employees in a unit or municipality (or more than 60 in total), the indemnity is a minimum of 6 and a maximum of 36 months of reference pay (art. 3 D.Lgs. 23/2015); after Constitutional Court rulings 194/2018 and 150/2020 the judge sets the amount within that range weighing seniority, company size, the parties' conduct and other factors. For employers at or below those thresholds the amounts are halved (art. 9), so the range is 3 to 18 months: Constitutional Court ruling 118/2025 struck down the former six-month cap.

## Side by side

| | Singapore | Italy |
|---|---|---|
| Reason needed | No, with notice | Yes, after probation |
| Notice | Contract, default 1 day–4 weeks | CCNL, by level and seniority |
| Pay in lieu | Yes | Yes |
| Process | Written notice | Written reasons; disciplinary procedure where relevant |
| Challenge | TADM within 1 month | Written challenge within 60 days, then court action |
| Remedy | Compensation or reinstatement for wrongful dismissal | Compensation in months of pay; reinstatement in some cases |

## Other ways employment ends in Italy

**Resignation.** Employees must resign online through the Ministry of Labour's procedure, giving CCNL notice. This rule exists to prevent signed blank resignations.

**Mutual agreement.** The parties can agree to end employment, usually with a settlement payment. To be final, the agreement is signed in a protected venue (for example, before a union or a labour office conciliation commission), which blocks later claims.

**Probation.** During a valid probation period, either side can end the contract without notice or reason.

**Collective dismissals.** Larger reductions follow a separate procedure. See [Retrenchment benefits in Singapore vs TFR and collective dismissal in Italy](/articles/retrenchment-benefit-singapore-vs-italy-tfr.html).

On any exit, the employee is owed TFR and accrued leave, and on most dismissals the employer pays the NASpI contribution ("ticket di licenziamento") to INPS. In 2026 the contribution is €649.73 for each 12 months of service in the last three years (41% of the €1,584.70 monthly NASpI cap), so up to €1,949.19 per employee; in a collective dismissal without a union agreement it is tripled (art. 2, paras. 31 and 35, Law 92/2012).

## Common questions from Singapore teams

**Can we write a Singapore-style termination clause into the contract?** You can state notice periods, but a clause allowing dismissal without reason after probation has no effect. The law on justified reasons is mandatory.

**Does a small team change the rules?** The reason is always needed. What changes for small employers is the size of the compensation if a court finds the dismissal unjustified, and some procedural steps.

**Can we just pay someone to leave?** Yes, and it is common. A negotiated exit with a settlement signed in a protected venue is often faster and more predictable than a contested dismissal.

**How fast can it be done?** A mutual agreement can be signed in days. A disciplinary dismissal takes at least the procedure time. Plan weeks, not a single day.

## What this means if you hire through an EOR

The EOR is the legal employer, so it issues any dismissal and runs the procedure. It cannot turn Italian law into Singapore law. If you want to end the employment of an Italian employee, expect the EOR to ask for a documented reason and to recommend either a justified-reason dismissal with the right paperwork or a negotiated exit.

Practical steps:

- use probation properly; it is your only no-reason window;
- document performance concerns as they arise, in writing;
- budget for notice, TFR and a possible settlement in your headcount planning;
- talk to the EOR before you tell the employee anything.

Compare more rules on [Italy vs Singapore](/italy-vs-singapore.html), read about notice and probation in our [Italian employment contracts](/italy-employment-contracts.html) guide, and model exit costs in the [cost calculator](/calculator.html).

## The bottom line

In Singapore, notice is the main protection. In Italy, the reason is. Build your hiring and performance management around that, and Italy is manageable.

Need help planning an exit? [Contact us](/contact.html).

<small>General information, not legal advice.</small>

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Source: https://hiringitaly.com/articles/termination-with-notice-singapore-vs-italy-dismissal.html · 2026-11-09