Employment contracts in English: what French labour law says

The basic rule: a written contract is drafted in French

For a contract governed by French employment law, everything starts with article L1221-3 du Code du travail. Its first paragraph is unambiguous: a written employment contract is drafted in French. It makes no difference that the company belongs to an American group, that the working language is English or that the employee is a native English speaker.

This requirement sits within the wider framework of loi n° 94-665 du 4 août 1994, known as the Toubon Law, covered in our article on documents that must be in French. The Labour Code itself is available on Legifrance.

Job titles in English

The same article covers jobs that can only be described by a foreign term with no French equivalent, as happens with some tech or finance titles. The term may stay, but the contract must then include an explanation in French of what it means. In practice: a sentence describing the role, not just the title.

The penalty: clauses that cannot be enforced against the employee

The final paragraph of Article L1221-3 states that the employer cannot rely, against the employee, on clauses that are detrimental to them in a contract concluded in breach of these rules. The text does not make the contract void; the penalty bites on the clauses. A non-compete, mobility or targets clause written only in English may therefore be unenforceable against the employee, while the employee can still rely on the clauses that favour them.

A foreign employee is entitled to a translation in their own language

Where the employee is a foreign national and the contract is in writing, Article L1221-3 provides that a translation is produced, at the employee's request, in their language. Three points to remember:

• the translation is into the employee's language, not necessarily English: a German employee can ask for German;
• both texts are equally authoritative in court, so the translation is a contractual document, not a courtesy copy;
• where the two texts differ, only the version in the foreign employee's language can be relied on against them. A translation error therefore works against the employer.

The practical consequence: a clause stating that the French version prevails in case of discrepancy does not override this rule. The only real safeguard is an accurate translation that matches the original.

Other HR documents are caught too

The contract is rarely the only document. Article L1321-6 du Code du travail requires French for the internal rules (règlement intérieur) and for any document setting obligations for employees or containing provisions they need to know to do their job. In practice this can include:

• the variable pay plan and target-setting documents;
• internal policies (remote working, expenses, IT charter);
• safety instructions.

The same article exempts documents received from abroad or intended for foreign nationals. This exemption is tricky to apply: a bonus plan drafted by the parent company and applied to staff in France deserves your lawyer's view before it goes out in English only. For these HR documents, Archive, our administrative and HR specialist, takes over.

Bilingual contracts: the method that keeps you out of trouble

1. Draft the French version first. It is the one the law requires and it must be complete, schedules included.
2. Freeze the text before translating. Any later change must be made in both versions, otherwise you create exactly the discrepancy Article L1221-3 turns against you.
3. Have the whole document translated, including schedules and references to the collective agreement, not just the clauses that seem important.
4. Present both versions side by side or one after the other, stating which one is the translation.
5. Have the English version checked by someone who knows the file (HR or legal): figures, dates, durations, amounts, party names.

Terms with no exact equivalent

French employment law has concepts with no mirror image in English or US law. Translating them too literally can mislead the employee; a descriptive equivalent, often followed by the French term in brackets, works better.

At Manuce, an employment contract goes to Thémis, our legal and contracts specialist, which works with this terminology and keeps each term consistent throughout the document. For the full translation process, see our page on translating an employment contract.

A worked example: a contract and its schedules

Take an employment contract with a variable pay plan and a remote-working policy attached, 4,000 words in total (about 10 pages), to be translated from French into English. On the day this article was written, the quote displayed by Manuce was:

Essential is enough to understand a contract you have received. For a document handed to the employee that will carry legal weight, choose Professional or Premium, which adds a cross-check review. If the same file is also needed in German and Spanish, the 30% three-language discount applies: €216 before discount, €152 in total at Professional level. VAT not applicable, article 293 B du CGI. The full price list is on our pricing page.

To get started, upload the Word file to the translation workspace: words are counted on the actual document, the quote appears before payment, an extract is translated free of charge and the English version arrives within minutes, with the layout preserved. No file is read by a human, servers are in France and your documents are never used for training (privacy policy).

What Manuce does not do

Article L1221-3 does not require a sworn translation. If, however, a foreign authority or consulate asks for a certified translation of the contract, for instance for a work visa, you will need a court-approved translator (traducteur expert près une cour d'appel): Manuce does not offer this service. Our guide to sworn translation explains the difference. Finally, a scanned contract with no text layer cannot be processed: start from the original Word file.