The Development and Implementation of the Right to Disconnect in Different Jurisdictions

Abstract

This article examines the development and implementation of the right to disconnect in selected jurisdictions, with particular attention to its legal foundations and its implications for employee well-being, productivity, and work–life balance. The central hypothesis is that explicit statutory regulation, supported by organizational practice, provides stronger protections for workers than reliance on general working-time provisions alone. The study applies doctrinal, comparative, historical, and socio-legal methods, and incorporates insights from a small-scale survey of remote workers. The analysis shows that while France and Italy have introduced comprehensive legislative frameworks, other countries, such as Romania and Japan, continue to rely primarily on working-time limits, and Canada is moving towards a mixed federal–provincial model. The article concludes that sustainable implementation of the right to disconnect requires not only statutory safeguards but also collective bargaining, cultural change, and sector-specific adaptations.