AI layoff laws in the US, UK and Philippines, compared
The short answer
In the United States there is no federal law that specifically covers AI layoffs. The rule that decides your notice is the WARN Act, and it counts headcount, not motives: 60 days' written notice before a mass layoff or plant closing at a site with 100 or more employees, with a mass layoff defined as an employment loss for at least 33 per cent of active employees (and at least 50 people) in a 30-day window. In the UK the equivalent is collective consultation: 30 days before the first dismissal for 20 to 99 redundancies, 45 days for 100 or more. The Philippines still runs on one month's notice and one month's pay per year of service, but the bill filed on 8 November 2026 would raise that to six months' notice and two months' pay.
The rule that decides everything is headcount, not cause
Almost every argument about AI layoffs starts in the wrong place. People ask whether AI is a lawful reason to dismiss someone. In the US, the UK and the Philippines, AI is not a separate category of dismissal, so the question that matters is how many people are going and over what period.
That is why a company can cut 200 roles one at a time and owe nothing beyond normal notice, while a company cutting 60 people in one site can trigger a statutory consultation. The technology is irrelevant to the trigger. It only becomes relevant afterwards, in the paperwork a court or tribunal may ask for.
United States: WARN, 60 days, and a threshold nobody mentions
The Worker Adjustment and Retraining Notification Act requires employers with 100 or more full-time employees, or 100 or more employees who together work at least 4,000 hours a week, to give at least 60 days' written notice of a plant closing or mass layoff. Notice goes to affected employees and to the state dislocated worker unit.
A mass layoff under the regulation means an employment loss at a single site of employment during any 30-day period for either at least 33 per cent of the active employees (excluding part-timers) and at least 50 people, or at least 500 employees. If your employer is below those numbers, WARN does not apply, and the notice you get is whatever your contract or state law provides.
Two consequences follow, and they are the ones most AI announcements ignore. First, WARN is cause-blind: it does not care whether the reason is a downturn, a merger or a model that writes support replies. Second, if a company says "AI replaced 40 people" at a site of 300, WARN almost certainly was not triggered, because 40 is under both the 33 per cent and the 50-person floors.
California: the first US state to name AI in the notice
California has done the thing other states have not. Senate Bill 951, signed in 2026 and effective 1 January 2027, expands what an employer must disclose when a mass layoff under Cal-WARN is caused in whole or in substantial part by an AI system or other automated technology.
Cal-WARN already requires 60 days' notice, and it covers establishments with 75 or more employees in the preceding 12 months, which is a lower bar than the federal act. SB 951 does not create a new notice period. It adds a disclosure: if AI is part of why the jobs are going, the notice has to say so.
That is a small sentence with a large effect. From January, a California employer cannot file a routine layoff notice and stay quiet about the automation that caused it. For workers, it creates a paper trail that did not exist before.
United Kingdom: 30 or 45 days, and no AI-specific rule at all
UK law has no separate AI redundancy category either. What it has is a hard consultation floor under the Trade Union and Labour Relations (Consolidation) Act 1992. Where an employer proposes 20 or more redundancies at one establishment within 90 days, it must start collective consultation with trade union or employee representatives at least 30 days before the first dismissal, or 45 days where 100 or more are proposed.
The Employment Rights Act 2025 adjusts how that threshold is applied and adds a protected period around consultation, but the 30 and 45 day figures stay. Consultation has to be carried out with a view to reaching agreement, which in practice means the employer must be able to show it considered alternatives, including redeployment.
Where AI enters the picture is evidence, not statute. A tribunal looking at whether a redundancy was genuine will want to see why the role disappeared, and "we bought a tool" is a weaker answer than it sounds if the tool needs a person to operate it.
Philippines: what exists now, and what is being proposed
The current Labor Code treats redundancy as an authorised cause: the employer must give written notice to the worker and to the Department of Labor and Employment at least one month before the intended date, and pay separation pay of at least one month's salary for every year of service.
Senate Bill 2563, filed on 8 November 2026, would add a specific article for AI and automation. Employers would have to show the system is genuinely being implemented, act in good faith for a valid purpose, exhaust reskilling and redeployment, apply fair selection criteria, consult affected workers, and notify DOLE at least six months ahead. Separation pay would rise to at least two months' salary, or two months' salary for every year of service, whichever is higher. It is a bill, not a law.
The three systems side by side
| Jurisdiction | Trigger | Notice before dismissals | Does AI change it? |
|---|---|---|---|
| US federal (WARN) | Mass layoff or plant closing, 100+ employees at a site | 60 days, in writing | No. Cause-blind. |
| California (Cal-WARN + SB 951) | 75+ employees at a covered establishment | 60 days | Not the notice, but AI must be disclosed from 1 January 2027 |
| United Kingdom | 20+ redundancies at one establishment in 90 days | 30 days (20 to 99), 45 days (100+) | No. Consultation rules apply regardless of cause. |
| Philippines (current law) | Redundancy as an authorised cause | 1 month to DOLE and the worker | No specific AI article |
| Philippines (SB 2563, proposed) | Dismissal caused by AI or automation | 6 months to DOLE | Yes, with reskilling and consultation conditions |
Six things to ask if AI is named in your layoff
- How many people, at how many sites, in what window? This tells you whether any statutory threshold is close to being met.
- Was the notice filed? WARN notices go to the state dislocated worker unit and are public in many states. In the Philippines, the notice goes to DOLE.
- Which roles are going and which are staying? If a role is being cut but the work continues, the selection criteria matter.
- What reskilling was offered, in writing? Under the proposed Philippine rules this becomes a condition, not a courtesy. In the UK it is central to whether consultation was meaningful.
- Is AI the cause or the story? Ask what percentage of the role the system performs today, not next year. A tool that drafts 60 per cent of the tickets still needs someone to handle the other 40.
- What is the pay calculation? Statutory minimums are floors. In the Philippines one month per year is the floor today and two months is proposed; in the US and UK there is no statutory redundancy pay for AI, only contract and notice.
If you are below the thresholds
Most AI-related cuts are below every threshold described here. A 30-person company cutting 8 people in the US triggers nothing under WARN, owes no consultation in the UK unless it is part of a larger establishment, and in the Philippines pays one month per year. That is the gap every new law is trying to close, and it is why the California disclosure rule and the Philippine bill matter more than they look: they are aimed at the small, frequent cuts that no headcount trigger catches.
For anyone in that situation, the practical answer is contractual rather than statutory. The notice you get is the notice in your contract. The pay you get is the pay your employer chooses to offer. Which is why the recall data from this month matters: if a fifth of AI cuts are later reversed, the terms of the exit are worth negotiating rather than accepting.
Questions people ask
Is it illegal to fire someone because of AI?
Not in itself, in the US, UK or Philippines. What is regulated is the process: notice periods, consultation, selection criteria and separation pay. California adds a disclosure duty from 1 January 2027 when AI is a substantial cause of a covered layoff.
Does the WARN Act apply to AI layoffs?
Yes, if the headcount thresholds are met. WARN does not look at the reason for the layoff, only at the number of employees and the site.
How much notice do I get in the UK?
For 20 to 99 redundancies at one establishment, collective consultation must start at least 30 days before the first dismissal. For 100 or more, at least 45 days. Individual notice under your contract is separate and comes on top.
What would the Philippines bill change?
Notice to DOLE would go from one month to six, separation pay from one month to two months per year of service (or two months' salary, whichever is higher), and employers would have to prove reskilling and consultation before cutting.
Do I get redundancy pay in the US for an AI layoff?
There is no federal redundancy pay requirement. WARN provides notice, not compensation. Any payment comes from your contract, a company policy or a state programme.
Where can I check if my employer filed a WARN notice?
State dislocated worker units publish WARN notices, and many states list them publicly. If your employer is in California, the notice must also disclose AI as a cause from 1 January 2027.