This article is part of our collaboration with International Policy Review at IE University. Photo Credits: Adobe Stock.
Abstract
Workplace burnout has surged across industries over the past decade, becoming a critical global issue. In response, governments and corporations have implemented various policies to address the crisis, ranging from legislative mandates to voluntary workplace guidelines. This article examines the policy approaches of France, Portugal, Canada, and Japan, analyzing their effectiveness in reducing burnout and improving employee well-being. Each country has tackled workplace mental health through different mechanisms: France’s Right to Disconnect grants employees the legal right to disengage from work communications outside working hours, while Portugal reinforces this right by imposing stricter penalties on employers who violate it. Japan’s Anti-Karoshi laws seek to combat death from overwork through overtime caps and mandatory health screenings, whereas Canada’s National Standard for Psychological Health and Safety promotes a voluntary, preventative framework designed to reduce psychological risks and foster mentally healthy workplaces. By evaluating these diverse approaches, this article identifies which policies are most effective based on enforcement mechanisms, industry adaptation, and cultural factors. The findings suggest that a one-size-fits-all model is insufficient, and instead propose a two-tiered approach establishing minimum universal protections alongside flexible, industry-specific adaptations. This strategy offers sustainable, long-term improvements in workplace well-being by ensuring that policies are both enforceable and flexible enough to adapt to evolving labor trends.
Keywords: Sustainable Development Goal 3, Workplace Burnout, Employee Well-being, Mental Health Policies, Labor Rights, Work-life Balance, Occupational Stress.
1. Introduction
The recognition of mental health as a critical aspect of overall well-being has gained momentum in recent years, prompting widespread efforts to mitigate work-related stress and psychological distress. Decades of research have established a direct link between burnout and severe health conditions including depression, insomnia, cardiovascular diseases, and musculoskeletal disorders. With nearly 60% of the global population over 15 years old employed in 2024, workplace mental health remains a pressing policy concern. According to the World Health Organization (WHO), all workers have the right to a safe and healthy working environment, yet psychological risks remain prevalent. These risks stem from job-related stressors such as demanding workloads, rigid schedules, workplace discrimination, exclusion, harassment, and bullying. When unaddressed, these stressors contribute to burnout—an occupational phenomenon formally recognized in the 11th Revision of the International Classification of Diseases (ICD-11).
Burnout manifests as chronic exhaustion, increased detachment from work, and declining professional efficacy. Beyond individual well-being, it also produces organizational inefficiencies, which reduce productivity, innovation, and workplace engagement while increasing absenteeism and error rates. The economic burden is equally significant: workplace burnout costs businesses billions annually in lost productivity and turnover.
Under the 2030 Agenda for Sustainable Development, the Sustainable Development Goal 3 “Good Health and Well-being” (henceforth referred to as SDG 3) encapsulates healthy lives and well-being across all ages. SDG 3 explicitly recognizes mental health as a priority, highlighting the need for mental illness prevention, treatment accessibility, and universal well-being. Moreover, because of mental health’s deep interconnection with other sustainability indicators like poverty reduction (SDG 1) and inequality reduction (SDG 10), comprehensive mental health policies are all the more urgent. Promoting mental health across all societal spheres—including, but not limited to, the workplace—is essential to the attainment of UN Sustainable Development Goals.
Facing rising concerns over workplace mental health, both corporate and government policies have implemented mechanisms to address mental health in professional settings. Workplace mental health regulations emerged in the United States in 1990 with the Americans with Disabilities Act (ADA), which prohibited workplace discrimination against individuals with mental health conditions. Since then, nations have refined their approaches to workplace mental health, implementing policies aimed at addressing psychological risks and burnout prevention. In 2008, Colombia became one of the first nations to mandate that companies collect and analyze data on psychological risk factors in the workplace and develop measures to enhance well-being accordingly. More recent legislation makes it clear that workplace mental health protections are strengthening, moving from general awareness measures to specific regulatory frameworks. A key example is France’s 2017 “Right to Disconnect” law, which grants employees the legal right to disengage from work-related digital communications outside standard working hours, ensuring better work-life balance and reducing digital burnout.
The expansion of workplace mental health policies signals a growing institutional acknowledgment of burnout as a global concern. Despite this progress, a critical disparity persists: while mental health regulations are increasing, burnout rates remain alarmingly high. This discrepancy raises an urgent question: Are workplace mental health policies truly effective in addressing burnout and promoting employee well-being?
Given the varied policy approaches across countries, analyzing the effectiveness of these initiatives is crucial. This article examines the workplace mental health policies of France, Portugal, Canada, and Japan, identifying the structural elements, enforcement mechanisms, and cultural factors that influence their success in mitigating burnout. By comparing these models, it seeks to uncover which policy frameworks are most effective in safeguarding workplace mental health and shaping the future of occupational well-being.
2. The Growing Crisis of Workplace Burnout
Workplace burnout has emerged as a global crisis with significant implications for both individual well-being and economic productivity. A 2022 survey conducted across 15,000 employees in 15 countries found that one in four workers reported experiencing burnout symptoms. More alarmingly, a Forbes report highlights that 82% of the workforce is at risk for burnout; the leading causes they identified include excessive workload (37%), exhaustion (40%), and financial strain (43%).
The rise in workplace burnout reflects a complex interplay of sector demands, evolving job expectations, and work-life pressures. Naturally, the prevalence of burnout varies across industries; finance, information technology, and healthcare are among the most affected. These sectors demand high performance, long hours, and constant availability, increasing psychological stress. Beyond industry-specific pressures, structural transformations in the labor market have reshaped the nature of work. While working hours have generally declined over recent decades, jobs have become more mentally demanding, requiring employees to remain perpetually available. On top of this, the rise of dual-income households — driven in part by increased female labor force participation — has forced many workers to navigate the career-family tradeoff, further amplifying stress.
Economically, burnout raises costs and reduces revenues through productivity decline, product quality deterioration, and operational inefficiency. This translates into severe earnings losses for employees: burnout-related sick leave contributes to a 15% annual income decline per worker, with long-term effects including labor market withdrawal or shifts to part-time employment. This trend has been exacerbated by the Covid-19 pandemic, which caused a 25% global surge in depression cases between 2020 and 2021. In response, governments have increasingly introduced workplace mental health policies aimed at addressing burnout. Yet the effectiveness of these measures remains contested. This raises a critical question: What should countries do to meaningfully reduce burnout rates and improve occupational mental health?
3. Workplace Mental Health Policies: A Global Perspective
3.1 France: The Right to Disconnect – Balancing Flexibility and Enforcement
Government policies addressing workplace mental health vary significantly across countries, reflecting differences in labor structures, cultural norms, and regulatory approaches. One major example is France’s “Right to Disconnect” law, a landmark regulation introduced in 2017 in response to rising digital fatigue and blurred work-life boundaries. In an era where professional communication is dominated by emails, phone calls, and instant messaging, this law grants employees the right to disengage from work-related communications outside of designated working hours, mitigating the risk of burnout caused by constant connectivity.
The law does not impose strict, universal rules but instead operates on a principle of negotiation and flexibility. Each company should seek to establish an agreement on digital disconnection, allowing businesses to adapt policies to their specific work culture. The phrase “should seek” is particularly important—while companies with trade union representation are legally required to engage in negotiations, there is no obligation to reach an agreement. This distinction reflects France’s commitment to contractual freedom, ensuring that while negotiations are mandatory, outcomes remain subject to corporate discretion. However, failing to attempt negotiations carries consequences: non-compliant employers face fines of up to €3,750 and a potential one-year prison sentence. The law therefore encourages companies to address burnout risks without imposing rigid mandates, a stark contrast to stricter policies seen in other countries.
3.2 Portugal: Strengthening Work-Life Boundaries Through Legal Penalties
Portugal took France’s Right to Disconnect a step further with the Remote Work and Right to Disconnect law, enacted in 2021, which explicitly prohibits employers from contacting employees after working hours except in emergencies. While the underlying aim remains the same, Portugal’s approach strengthens enforcement, eliminating the ambiguities present in the French model. Embedded directly into the Portuguese Labour Code, the law allows for legal penalties not just for procedural failures, like in France, but for actual breaches of work-hour boundaries—making violations enforceable based on outcomes rather than intentions. Employers who breach the regulation face fines of up to €9,690, and affected employees can pursue legal action, including injunctions, breach of contract claims, and compensation requests. Unlike France’s negotiation-based approach, which relies on companies reaching internal agreements, Portugal’s framework provides clear legal consequences for non-compliance, reinforcing the idea that work-life boundaries should not be left to corporate discretion but legally protected as a worker’s right.
3.3 Canada: A Voluntary Approach to Mental Health in the Workplace
Another approach to workplace mental health policy focuses on guidance rather than enforcement, emphasizing voluntary action over legal mandates. The first law of this kind is Canada’s 2013 National Standard for Psychological Health and Safety, which provides a voluntary framework that organizations can adapt to in order to promote healthy work environments. The areas of focus recommended include, but are not limited to, supporting employees in addressing psychological health concerns; fostering a workplace culture of respect and inclusion; and promoting a balance between work, family, and personal life. While its flexibility allows organizations to tailor mental health initiatives to their specific needs, its lack of attached legal obligation raises questions about adoption rates.
3.4 Japan: Combating Overwork Through Anti-Karoshi Legislation
Some countries have taken a more severe regulatory approach, particularly in response to extreme workplace conditions. One of the most notable examples is Japan’s Anti-Karoshi measures which were introduced to combat karoshi—death from overwork. Unlike Canada’s voluntary guidelines or France’s digital disconnection policies, Japan’s laws directly target excessive working hours. Overwork is an issue that has shaped the country’s corporate culture for decades; to address this crisis, Japan has implemented a series of legislative measures, including mandatory health checks for employees working excessive hours; legally enforced overtime caps; and expanded employer responsibilities for monitoring, reporting, and mitigating overwork-related risks. These policies are monitored and enforced by the Ministry of Health, Labour, and Welfare, which conducts workplace inspections and investigations. Employers found violating these regulations face fines of up to ¥300,000 (approximately equivalent to €1,870) and, in severe cases, imprisonment for up to six months.
4. Tailoring Mental Health Policies to National Workforce Challenges
The regulatory responses to workplace mental health are clearly varied. From strict enforcement mechanisms to voluntary guidelines, nations have tailored their policies to address the specific causes of burnout most prevalent in their workforce.
Japan, with its historically long working hours and deeply ingrained overwork culture, focused on reducing excessive overtime and chronic stress through legal overtime caps—generally limiting overtime to 45 hours per month and 360 hours per year—and health monitoring. The urgency of addressing karoshi (death from overwork) necessitated a strict regulatory approach with clear penalties for non-compliance. France, on the other hand, faced a different burnout trigger: constant digital connectivity. With employees increasingly expected to remain available beyond office hours, its Right to Disconnect law sought to redefine work-life boundaries by granting employees the legal right to disengage from work communications.
Portugal, building on France’s initiative, strengthened enforcement mechanisms in response to one of the highest remote work rates post-COVID-19. Recognizing the risks of digital exhaustion and blurred professional-personal boundaries, Portugal explicitly prohibited employer contact outside working hours, making non-compliance a punishable offense rather than a negotiable workplace agreement.
Meanwhile, Canada’s approach reflects a workplace culture where burnout stems primarily from psychological stress rather than excessive working hours. Issues such as job insecurity, high workloads, and lack of employer support led Canada to adopt a preventative approach, introducing a voluntary National Standard for Psychological Health and Safety to encourage organizations to proactively address mental health risks before they escalate into burnout.
5. Measuring the Impact: Successes and Limitations of Workplace Mental Health Policies
Despite the varied approaches to workplace mental health, studies consistently highlight the positive effects of policy implementation. In France, 92% of workers in companies that enforce the Right to Disconnect policy reported that their working hours aligned well with their personal life, compared to 80% in companies without such policies. Furthermore, 29% of employees in these companies expressed high job satisfaction, nearly double the 15% in companies without the regulation. Similarly, Japan’s legislative efforts led to a 26% decrease in overwork-related cerebrovascular and cardiovascular diseases (CCVD), demonstrating measurable health benefits. In Canada, a national study of over 1,000 organizations found that while only 1.7% had fully implemented the National Standard for Psychological Health and Safety and 20.3% had adopted some of its elements, over 71% anticipated further adoption within the year. Reported outcomes included greater job satisfaction, organizational reputation, and a reduction in absenteeism rates.
While these figures underscore the benefits of mental health policies, their effectiveness cannot be measured solely through statistical data—enforcement mechanisms and cultural adaptation play a critical role in determining long-term impact. A key issue is enforceability. France’s flexible approach allows room for incomplete compliance, weakening its impact. This is evident in data from 2017, which found that 78% of executives still checked work emails outside working hours, despite the law’s existence. Portugal’s policy, being more recent, lacks extensive statistical assessment, but its strict enforcement measures and financial penalties may serve as a stronger deterrent to non-compliance. Japan’s case presents a different challenge. Despite legislative success in reducing health risks, 1 in 10 workers still exceed 80 hours of overtime per month. Here, cultural resistance rather than legal enforcement limits the effectiveness of government intervention. Deeply embedded corporate norms continue to promote overwork, leading to underreporting and loopholes that undermine official monitoring efforts.
Canada’s model, however, should be evaluated within its own unique context. Unlike France, Japan, or Portugal, Canada already ranks among the top ten countries globally for work-life balance, reducing the urgency for strict legal intervention. Its voluntary approach should not be seen as a failure of enforcement but rather as a strategic framework for long-term mental health sustainability. By allowing companies to adopt policies at their own pace, Canada’s model serves as an example of how nations can transition from crisis management to proactive awareness-building, fostering a corporate culture where mental health becomes an intrinsic value rather than a regulatory obligation.
6. Policy Recommendations: Building a More Effective Mental Health Framework
Analyzing the approaches taken by France, Portugal, Canada, and Japan, it becomes evident that effective workplace mental health policies must be tailored to the specific challenges each country faces while simultaneously addressing underlying systemic issues to foster long-term occupational well-being. Given the prevalence of workplace burnout, Portugal’s strict enforcement model, including financial penalties for non-compliance, should serve as a foundation for governments seeking to establish a minimum standard for employee mental health protections. This baseline framework should include universal protections, such as guaranteed time off from work communications and clear legal boundaries to prevent digital overwork. However, rigid, one-size-fits-all mandates risk alienating industries with different operational demands. From this baseline, France’s negotiation-based approach offers a valuable counterbalance, allowing companies to adapt mental health policies based on industry-specific needs while still maintaining legally protected worker rights. A two-tiered policy model—combining Portugal’s strict enforcement with France’s built-in flexibility—could ensure that companies genuinely integrate mental health policies into their structures rather than implementing them superficially or fleetingly. By ensuring minimum legal protections while allowing tailored execution, this approach creates sustainable, industry-specific mental health strategies that are both enforceable and adaptable.
To prevent work-driven mental health crises, a proactive approach is needed—one that identifies risks before they escalate into widespread occupational health issues. A crucial step would be to require annual psychological risk assessments for employees in high-risk industries such as finance, healthcare, and technology, where burnout levels remain disproportionately high. Canada’s model provides a blueprint, with independent agencies responsible for monitoring and reporting employee well-being. However, to ensure broad and meaningful adoption, these assessments should be mandatory rather than voluntary, ensuring that companies are held accountable for their employees’ mental health before burnout reaches an irreversible stage.
While regulatory enforcement through fines and penalties has proven effective in certain contexts, it is not always sufficient to ensure meaningful or sustained compliance—particularly when loopholes exist or when enforcement clashes with entrenched cultural norms. Punitive measures—such as Japan’s Anti-Karoshi legislation—have yielded measurable improvements, but they cannot by themselves eliminate mental health risks in the workplace. As discussed earlier, despite legislative success in reducing overwork-related health conditions, 1 in 10 workers in Japan still exceed 80 hours of overtime per month. Here, cultural resistance rather than legal enforcement limits the effectiveness of government intervention. Deeply embedded corporate norms continue to promote overwork, contributing to underreporting and regulatory blind spots. This underscores the need for a more holistic approach that combines enforcement with proactive engagement, cultural change, and organizational accountability.
Incentive-based policies offer an alternative by motivating companies to proactively foster employee well-being, rather than merely avoiding penalties. Governments could introduce tax benefits for companies that demonstrate a reduction in overtime hours or track a steady decline in employee burnout rates. These financial incentives would encourage organizations to develop and enforce their own internal policies to achieve measurable improvements in mental health. By shifting the narrative from punishment to proactive engagement, companies would be more likely to tailor solutions to their specific workplace challenges, following Canada’s voluntary approach while still striving for better overall results.
Beyond national policies, Canada’s voluntary standard presents an opportunity for cross-national collaboration on workplace mental health standards. A global framework would extend Canada’s flexible model beyond national borders, fostering cross-industry benchmarking and international cooperation. As companies begin to observe positive results from organizations that successfully implement mental health initiatives, there would be a ripple effect, increasing awareness of the problem and motivation to align with workplace well-being standards. Additionally, as mental health becomes an established corporate norm, reputational incentives could play a crucial role in ensuring compliance without the need for strict legal mandates. Companies that prioritize employee well-being would gain a competitive advantage, as workplaces known for healthy work environments attract top talent and improve employee retention.
7. Conclusion: The Future of Workplace Mental Health
As mental health awareness grows, it is time for companies to recognize employee well-being as an essential component of a sustainable workforce. The policies examined in France, Portugal, Canada, and Japan illustrate the impact that government-led initiatives can have on reducing burnout and improving workplace mental health. However, these case studies also highlight the need for nuanced, context-specific approaches rather than a one-size-fits-all model. To develop effective and lasting solutions, countries must assess high-stress industries, cultural attitudes toward work, and the enforcement mechanisms necessary for real compliance. While strict penalties may be effective in ensuring adherence in some cases, voluntary incentives and corporate-driven initiatives can help embed mental health support into long-term organizational culture.
Moreover, workplace mental health cannot be seen in isolation—it has far-reaching implications for economic productivity, social equity, and overall public health. The emergence of remote work, AI-driven labor, and automation presents new challenges and uncertainties, reinforcing the urgency for governments and institutions to take proactive action. As the workforce continues to evolve, so must the policies designed to protect and support it.
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