Introduction 

When it comes to employing staff across borders, assuming legal similarities between English-speaking jurisdictions is a mistake I’ve seen too often. While Alderney is part of the Bailiwick of Guernsey in the Channel Islands, and broadly aligned with UK customs and expectations, it has a distinct legal system. Compare this with the United States - a federal country with layered employment laws - and the contrasts become even more striking.

Understanding these differences isn’t just about compliance - it’s about avoiding risk, protecting your people, and setting your international operations up for success. Whether you’re onboarding remote workers, hiring contractors, or opening offices, here’s what every employer should know.

Quick Tips

• Don’t assume UK laws apply to Alderney without checking Guernsey-specific legislation.

• In the US, always check both state and federal law - they can differ significantly.

• Avoid using standard UK contracts for US or Channel Islands hires.

• Misclassifying contractors can lead to fines in both regions.

• Always check social security and tax obligations when hiring across jurisdictions.

Employment Status and Contracts 

One of the biggest risks for international employers is the use of generic contracts. In Alderney, employment is governed under the Employment Protection (Guernsey) Law, which differs from UK law in areas such as redundancy and dismissal processes.

The US, meanwhile, is largely defined by 'at-will' employment - unless contracts state otherwise, either party can terminate employment at any time. However, this varies by state and is also shaped by federal anti-discrimination and wage laws.

If you’re hiring across these two regions, contracts should be drafted or reviewed with local legal input. I recently supported a client with dual hires in Alderney and New York - both roles were remote, but the legal frameworks were worlds apart. One required custom termination clauses, the other required clear policy exclusions around severance.

Worker Rights and Protections 

In Alderney, employment rights are gradually expanding. The new Discrimination Ordinance (2022) is a key step, offering protections on grounds such as race, disability, and religion - though implementation is still bedding in. Maternity and annual leave entitlements are improving but remain distinct from UK benchmarks.

In the US, rights differ by state. There is no federally mandated paid holiday, and protections such as paid sick leave or parental leave are inconsistently applied. Employers must also comply with Equal Employment Opportunity Commission (EEOC) guidelines and may need to meet state-level obligations for accommodations or benefits.

Employers need to document policies clearly, deliver consistent onboarding, and regularly review obligations - particularly for workers in states like California, where rules are stricter than the federal baseline.

Tax and Social Security 

Tax is where things often go wrong.

Alderney does not have a separate social security system from Guernsey, but employers must register and deduct contributions accordingly. You’ll also need to confirm residency status and understand if income tax obligations fall within the Guernsey regime.

In the US, employers must withhold and remit federal income tax, social security, Medicare, and often state taxes. For remote workers, things get complicated quickly - I’ve worked with clients whose well-meaning arrangements triggered tax obligations in multiple states, simply due to where the employee resided.

If you’re employing people across both Alderney and the US, tax planning and local payroll knowledge are essential. Don’t assume your UK payroll team can simply ‘add’ these workers in.

A Real Example: Getting It Right Early 

A client of ours, a growing fintech firm, planned to hire a data analyst in Alderney and a business development manager in Texas. We helped them set up compliant contracts, register for local tax and employment schemes, and clarify expectations around notice, working time, and data security. By investing upfront in proper onboarding, they avoided the costly process of rehiring and retrospective contract fixes down the line.

Final Thoughts 

Even within jurisdictions linked to the UK, like Alderney, labour laws can look very different - and when compared to the US, the complexity multiplies. Getting it wrong is expensive. But getting it right? It positions your business as an employer of choice, wherever your people are based.

What’s next for your global people strategy? 

Book a free compliance check-in or HR audit with ThinkGlobal HR. Whether you’re exploring expansion, managing cross-border teams, or just want to avoid missteps, we’re here to support you with clarity, confidence, and compliance.