UK vs US sales hiring: notice, at-will, equity and benefits

The biggest differences between UK and US sales hiring are timing and total cost: UK sellers usually work one to three months' notice under contract, while most US sellers are employed at will and give two weeks; and a US offer must cover healthcare and a richer cash and equity mix, while a UK offer carries employer National Insurance, pension and a statutory 5.6 weeks' holiday. Companies hiring sellers in both markets need different timelines, offer structures and budgets for each.

This guide compares UK vs US sales hiring for founders and sales leaders expanding across the Atlantic, whether a London company opening a US office or a US company building a UK team. It covers notice periods and at-will employment, restrictive covenants, commission plans, equity, benefits and holiday, with a side-by-side table and a checklist.

UK vs US sales hiring at a glance

Notice periods vs at-will: how timelines differ

The single most practical difference for hiring teams is how long it takes a seller to start.

In the UK, notice periods are set by the employment contract. GOV.UK sets out the statutory minimum an employer must give: one week after one month's service, then one week per year of service from two to 12 years, up to 12 weeks. Contracts usually provide more, and for sales roles one month is common for individual contributors while three months is common for senior account executives, sales managers and directors. Some leadership contracts run to six months. Garden leave clauses allow an employer to keep a departing seller at home, on full pay, for some or all of the notice period, out of contact with customers.

In the US, employment is generally at will. According to TriNet, every state except Montana follows the at-will rule; Montana's Wrongful Discharge from Employment Act requires good cause for dismissal after a probationary period. In practice, US sellers give two weeks' notice as a professional courtesy and many employers end employment on the day of resignation, particularly for sellers with access to customers and pipeline.

Non-competes and restrictive covenants

Sales hiring often involves a candidate moving between competitors, so restrictive covenants matter more than in most functions.

In the UK, a non-compete is treated like any other restraint of trade clause: unenforceable unless the employer shows it is reasonable, and tested by the courts if challenged. A Department for Business and Trade working paper published on 26 November 2025 estimated that about 5 million employees in Great Britain have a non-compete in their contract, that a typical duration is around six months, and that clauses longer than 12 months are only likely to be upheld in exceptional circumstances. The paper sets out options including a statutory length limit, a ban below a salary threshold, or an outright ban. For now, sales contracts commonly combine a non-compete with non-solicitation and non-dealing clauses covering customers the seller worked with.

In the US, the position depends on the state. The Federal Trade Commission's attempt at a national ban on most non-competes did not take effect: on 5 September 2025 the FTC voted to dismiss its appeals and accept the court ruling vacating its Non-Compete Clause Rule. California treats employee non-competes as void, and laws effective in 2024 extended that position to contracts signed outside the state and gave employees the right to sue an employer that tries to enforce one. Other states range from broadly permissive to restrictive, often with salary thresholds or notice requirements.

Commission plans: how sales comp differs

The structure of sales pay is similar in both markets, a base salary plus variable pay at target (OTE), but the mix, the paperwork and the treatment of commission on departure differ.

• Pay mix: US AE plans more often run close to a 50:50 base-to-variable split (The Bridge Group's 2024 AE benchmark reported a median of 53:47), while UK plans frequently weight more towards base. Sales leaders in both markets tend to have a higher base share.
• Written plans: In California, Labor Code section 2751 requires anyone paid on commission to receive a written, employer-signed agreement explaining how commissions are computed and paid. In the UK, the commission plan usually sits in a separate policy referred to in the contract; make sure it states when commission is earned and what happens on leaving.
• Commission after leaving: UK and US plans both commonly pay only on deals closed, invoiced or paid while employed. In a long UK notice period, garden leave can mean a seller earns nothing further on deals they sourced. Candidates will ask.
• Draws and guarantees: US offers commonly include a non-recoverable draw or guaranteed commission during ramp. UK offers more often guarantee a share of variable pay for the first one or two quarters.
• Pay ranges: California's SB 1162 requires employers with 15 or more employees to include a pay range in job postings, including those posted by recruiters on their behalf. UK employers are not generally required to publish ranges, but many now do.

For current role-by-role base and OTE ranges in both markets, see /salary-guide and /specialisms/account-executives.

Equity: options, RSUs and EMI

Equity plays a larger part in US sales offers than in UK ones, particularly in the Bay Area and New York. US candidates at venture-backed companies expect an option grant and will ask about the strike price, the latest preferred share price, the vesting schedule, the cliff and the exercise window after leaving. At later-stage and public companies, restricted stock units (RSUs) are common.

In the UK, equity has become standard at venture-backed technology companies, but sellers often weight it less heavily than cash and are more sceptical of paper value. Qualifying UK companies can grant options under the Enterprise Management Incentive (EMI) scheme, which offers favourable tax treatment for employees, subject to HMRC's limits on company size and the value of options granted. Larger companies and US parents with UK staff often use unapproved options or RSUs instead.

Benefits and holiday: what each market expects

Healthcare

Healthcare is the biggest structural difference in total cost. In the US, an employer-sponsored health plan is a core part of a competitive offer. KFF's 2025 Employer Health Benefits Survey, published in October 2025, put average annual premiums at $9,325 for single coverage and $26,993 for family coverage, with workers contributing on average $1,440 and $6,850 respectively. Employers pay the rest. For a seller with a family, the quality and cost of the health plan can decide between two similar offers.

In the UK, the NHS provides healthcare, so private medical insurance is a valued perk rather than a necessity. It is common in technology sales offers but rarely decisive.

Pension and retirement

UK employers must automatically enrol eligible employees into a workplace pension. Under the minimum rules, total contributions must be at least 8% of qualifying earnings, with at least 3% from the employer. Many technology employers pay more, and salary sacrifice arrangements are common. In the US, 401(k) plans are widespread and an employer match is a standard expectation at established companies, but there is no legal requirement to offer one.

Holiday and paid time off

UK workers on a five-day week are entitled to 5.6 weeks of paid holiday, 28 days, which employers can count bank holidays towards. Technology companies commonly offer 25 days plus bank holidays. In the US, the Department of Labor confirms that the Fair Labor Standards Act does not require payment for time not worked, such as vacations or holidays; paid time off is a matter of employer policy. Many US technology companies offer a fixed PTO allowance or an unlimited PTO policy, and candidates will often ask how much time people actually take.

Employer costs beyond salary

A UK sales offer carries employer National Insurance contributions of 15% on earnings above the secondary threshold of £5,000 a year for 2025/26, plus employer pension contributions. Commission is subject to National Insurance too, so a high-earning seller's variable pay adds materially to employment costs. In the US, employers pay Social Security, Medicare and federal and state unemployment taxes, and the health plan is typically the largest cost after salary. When comparing a UK and a US hire, model total employment cost at OTE, not base salary alone.

Hiring across both markets: a practical checklist

Worked example: one role, two offers

This is an illustrative comparison, not a pay benchmark. Imagine a company hiring a mid-market account executive in London and another in New York, each with the same quota.

• London offer: base and OTE set from UK data, often with a slightly higher base share; 25 days' holiday plus bank holidays; employer pension above the statutory minimum; private medical insurance; an EMI or unapproved option grant; one month's notice expected from the candidate
• New York offer: base and OTE set from US data, with variable pay closer to half of OTE; a health plan with a meaningful employer contribution; a 401(k) with a match; a PTO policy; an option grant the candidate will scrutinise in detail; a start in two to three weeks
• Cost to employer: the US hire typically costs more in cash and benefits; the UK hire carries employer National Insurance and pension on top of salary and commission
• Process: the UK search needs longer from offer to start; the US search needs a faster interview process and a firmer counter-offer plan

Neither market is cheaper in every respect. What catches companies out is applying one market's assumptions to the other: offering a US seller a UK-style benefits package, or expecting a UK seller to start in two weeks.