WARN Act and Layoffs in Professional Services — What Consultants, Accountants, and Law Firm Staff Should Know

Layoffs at consulting firms, accounting practices, law firms, and marketing agencies rarely look like a factory closure: a practice group is dissolved, an office lease is not renewed, or a client account is lost and thirty people are gone by Friday. The WARN Act still applies to those cuts — but the rules were written with factories in mind, and office work changes how they fit.

Layoff Atlas counts 681 WARN notices covering 61,493 reported workers in the current 90-day window, with 29 filings where the worker count was not available. The heaviest upcoming week is November 22, with 6,614 workers scheduled. California (22,043 workers) and Washington (17,333) together account for about 64% of all reported workers. These are reported plans, not confirmed job losses — but the pattern is clear: layoffs are not confined to manufacturing or tech.

When WARN applies to a firm

The federal WARN Act covers employers with 100 or more full-time employees. Two triggers matter for professional-services firms:

• Plant closing: 50 or more full-time employees lose their jobs because a single site of employment shuts down.
• Mass layoff: 50 to 499 employees are laid off and they make up at least 33% of the workforce at that site, or 500 or more employees are laid off regardless of percentage.

When a trigger is hit, the employer must give 60 calendar days' written notice to affected employees, their union if there is one, the state dislocated worker unit, and the local government. Part-time employees — those working fewer than 20 hours a week, or employed for fewer than 6 of the last 12 months — do not count toward the thresholds, but they are still entitled to notice.

The remote-work question

The hardest question is what counts as a "single site of employment" when half the team works from home. Federal guidance treats remote workers as belonging to the office they report to or receive assignments from — not their living room. A firm closing its Chicago office and laying off 60 people, including 20 remote workers who reported to Chicago, has likely closed a single site with 60 affected workers.

For fully distributed firms with no office at all, the analysis is murkier, and employers sometimes conclude no single site exists. That is not a safe assumption: the Department of Labor looks at where workers are assigned and managed. If you work remotely, ask in writing which site your position is assigned to — the answer decides whether WARN's protections reach you.

Small offices, big cuts

Professional-services layoffs often come in small batches: twelve here, twenty there, none hitting the federal threshold on its own. But WARN aggregates layoffs at a single site within any 90-day period: two rounds of 30 at the same office within three months add up to 60 — and the notice obligation applies.

State mini-WARN laws lower the bar further, and they matter more in office-heavy states. California requires 60 days' notice when 50 or more employees are affected, regardless of what percentage of the site that is. New York requires 90 days' notice and triggers at 25 employees when they are a third of the site. New Jersey requires 90 days' notice for 50 or more. Illinois requires 60 days when 50 or more full-time employees are affected at a firm with 75 or more. A firm that escapes federal WARN may still owe notice under state law.

What happens without notice

A WARN notice must state whether the layoff is permanent or temporary, the expected separation date, whether bumping rights exist, and a company contact. Workers can check whether a notice was filed by searching their state's WARN registry or the Layoff Atlas tracker.

An employer that skips the notice can be liable for back pay and benefits for each day of the violation, up to 60 days, plus attorneys' fees. WARN is a notice law, not a payment law — but the back-pay liability often pushes employers to negotiate severance instead.

Project staff and the 60 days

The WARN Act has a narrow exception for project work, common in consulting and engineering: employees hired for a specific project, with the understanding that the job ends when it is completed, are not covered when the project actually ends. The exception does not protect a firm that keeps the same people on rolling projects for years — the understanding at hiring has to be real and documented. Contractors supplied by a staffing agency are generally the agency's employees, not the client's. But if you are on the firm's own payroll, you count — even if your title says contractor and you bill by the hour.

If you are inside a 60-day notice period, use it: file for unemployment as soon as you are eligible, check COBRA deadlines, get references in writing while managers are still reachable, and review any non-compete before you sign a severance agreement.

The numbers in context

The six-week calendar totals 27,071 workers: November 15 (5,537), November 22 (6,614, the heaviest), November 29 (6,202), December 6 (857, the lightest), December 13 (5,310), and December 20 (2,551). Virginia (2,556), Maryland (2,547), and Texas (2,419) round out the top five behind California and Washington.

Recent filings in the data include a 39-worker UBS filing in Weehawken, New Jersey, effective February 2, 2027, and a 99-worker manufacturing closure in Logansport, Indiana, effective January 15, 2027. Office layoffs are reported in the same registries as factory closures — and workers in those jobs have the same right to 60 days' notice.

Data source: Layoff Atlas