Insights: Employment | Benefits | Mobility – Q1 2025 | Insights

Welcome to Insights, our regular publication highlighting key employment, benefits and mobility developments.

In the last edition of Insights, we highlighted upcoming areas of interest for businesses, including new laws, regulations and standards. With 2025 well underway, this edition covers some of the ongoing challenges and opportunities:

Washington Update
Employment Investigation Checklist: Key Steps for Employers
The Right to Disconnect Across Jurisdictions
United States: Voluntary Fiduciary Correction Program Updated with Self-Correction Feature
United Kingdom: Pensions – Updated Guidance on Employer Covenant Assessment

We also highlight key recent global employment, benefits and immigration updates, in case you missed them.

We are delighted to share this edition of Insights with you and hope you find it helpful. If you have any questions, please contact any member of the global Employment & Benefits team.

Washington Update

With President Donald Trump in office and Republicans in control of both houses of Congress, significant policy shifts have already taken place, with more on the horizon. Our team is closely monitoring all Executive Orders and other developments, keeping clients informed and ahead of the curve so they can quickly adapt to the evolving policy landscape and its potential impact on their organizations.

Employment Investigations Checklist

In recent years, internal investigations into employee complaints and employee conduct have been on the rise across a variety of industry sectors. Employment (or workplace) investigations can take many forms, and can be instigated by the employer, by an employee, or by a third party (such as a regulator, vendor, or a customer). For example, investigations are frequently a critical component in addressing disciplinary issues and grievances relating to bullying and harassment allegations, as well as whistleblower complaints. With many employers operating internationally, the need for investigations to cross borders has also increased, adding another layer of complexity to an already sensitive process.

The Right to Disconnect Across Jurisdictions

The “right to disconnect,” or the ability of workers to disconnect from work-related communications and activities outside their normal working hours, has become a pressing issue following the COVID-19 pandemic and the widespread shift to remote and flexible working. While some workers may appreciate the increased autonomy and flexibility that remote working offers, others may face challenges in maintaining a healthy work-life balance, managing expectations and boundaries, and avoiding burnout and stress. Employers should be aware that there are various approaches to the right to disconnect across jurisdictions.

United States: Voluntary Fiduciary Correction Program Updated with Self-Correction Feature

Effective March 17, 2025, an updated Voluntary Fiduciary Correction Program (VFCP) simplified administrative and procedural requirements by adding new self-correction options, clarifying the transactions eligible for correction through the VFCP, and expanding coverage of transactions eligible to be corrected under the program. Amendments to Prohibited Transaction Exemption (PTE) 2002-51 accompanied the updated VFCP.

United Kingdom: Pensions – Updated Guidance on Employer Covenant Assessment

A new funding regime for defined benefit pension schemes in the United Kingdom came into force in September 2024. It introduces a legal requirement for trustees to assess the strength of the employer covenant. In light of the new regime, the Pensions Regulator has updated its guidance for trustees on employer covenant assessment. Employers need to understand what requirements are being placed on trustees in relation to covenant assessment and monitoring, what support and information they may require from the employer, and the interaction between the guidance and corporate activity.