Are there developed countries where elected officials can easily terminate government workers?

Question

As per the answer to Can the US President fire government employees for poor performance? it seems like government employees are very hard to fire in the US. Are there developed countries where this isn’t so and elected officials can terminate any government worker with ease?

I presume government employees are quite easy to fire in places like China or Russia, but curious if any developed countries share the same practice.

Update

Definition of "easy to fire": the head of the state/government (or their secretaries) can terminate any person directly employed by the government on the spot, without the possibility of appealing the decision. Said employee might receive some compensation and 3+ months of severance, but their employment is immediately terminated.

Possible Refinement

The question might be refined in this way: Are there any OECD countries where rank-and-file government employees (as opposed to top level political appointees) can be fired without cause?

Answer 1

In germany: Yes, for certain high-level bureaucrats.

In Germany, some high-level posts are designated to be a Politischer Beamter (literally: political civil servant).

According to law (§ 30 Abs. 1 BeamtStG) a Politischer Beamter must "agree with the fundamental political positions and goals of the government". Therefore they can be put on temporary leave (einstweiliger Ruhestand) by the government (they cannot be fired though, and will continue to be paid, albeit at a lower rate).

A Politischer Beamter is sort of a hybrid between a government worker and a politician: They are legally government workers (specifically a Beamter, with special rights and responsibilities, but not elected) - however, they hold an office with so much responsibility that they have to make political decisions.

Politische Beamte are typically high-ranking officials, such as a Staatsekretär (the highest-ranking government worker in a ministry, directly under the minister). Politische Beamte are fairly rare - at the federal level there were 167 of them in 2010, out of a total of about 180.000 federal government officials.

---

However, apart from that, government workers are very hard (almost impossible) to fire unless they severely violate their duties, and elected politicians do not have special rights to fire them.

Answer 2

No.

Two things to keep in mind here:

1. Being a "Developed" nation implies that a justified and fair procedure exist for any government action. An independent judiciary safeguards such procedures.

2. Governments come and go, but the bureaucracy remains - bureaucrats are the backbone of any government, and no government likes to piss them off. That is why they also often have additional legal safeguards to protect them from political bias (as governments of different ideologies keep changing in a democracy), like clear guidelines on how to punish or dismiss them.

So, in any democracy, if an elected official is unhappy with some bureaucrat, the common procedure is to file a complain through the established procedures. Depending on how the law / rules / regulations are, an official, at worst, can be suspended pending the enquiry. Outright dismissal only happens in very rare case like corruption or any other criminal activity (again, this is rare because "developed" nations also subscribe to the principle of "innocent until proven guilty").

For the example you cited (of an FBI boss complaining to the President that he couldn't deliver because his subordinates were being lazy), what would realistically happen is that the President would start the process of finding a replacement for the current FBI chief for doing their job poorly!

Remember, that it is the FBI chief's job to get work done from his subordinate, and not bother the President with insignificant issues. In fact, that is why high-ranking bureaucrats have the powers to take actions against errant junior officials (up to a certain level) without needing to get government permission for the same.

(And note that even if any bureaucrat is punished or fired after an official enquiry, they still have the option of approaching the judiciary, and appealing their punishment or dismissal.)

Answer 3

In united-states, yes, but to a limited extent. Of the over two million civilian civil servants employed by the US federal government, the President can only fire about four thousand of them. These 4000 or so positions are listed in the Plum Book. The Plum Book says there are over 7000 positions that can be appointed (and most of them capable of being fired) by the President, but many of those are either perpetually vacant or are effectively career civil servant positions. This site, along with many others, say the actual number is about 4000. The President can appoint but cannot fire some of those positions. These are the non-competitive positions in the federal government's independent agencies. That's not a lot of people, so about 4000 remains the correct number.

President Reagan fired (and blacklisted) almost all of the air traffic controllers in 1981, and these were merit-based civil servant positions as opposed to presidentially-appointed positions. The loophole for that mass firing was that the air traffic controllers went on strike, thereby violating federal law that precludes strikes by civil servants.

President Trump attempted to create a new Schedule F that would have increased the number of presidentially-appointable and hence presidentially-firable civil servants by a factor of ten or more. His executive order was never implemented and was rescinded three days into President Biden's administration. However, the loophole President Trump's team found still exists. Congress has tried multiple times in the last two years to close that loophole but has failed each time.

Prior to 1883, when the US wasn't quite a developed nation, the federal government civil service used a spoils system ("to the victor belong the spoils"). This resulted in a lot of corruption, a lot of turmoil, and arguably the 1881 assassination of President Garfield. The Pendleton Civil Service Reform Act of 1883 changed the spoils system into a merit-based system, for the most part. Presidents can still appoint top civil service positions, but this capability is limited.

Answer 4

In Australia - yes, for the Secretary of each Department only.

This is covered in the Public Service Management Act, S58

In the case of the Secretary of the Prime Minister and Cabinet (PM&C) Department, the appointment is made by the Governor-general (figurehead President) on the advice of the Prime Minister. They are the most senior public servant in Australia.

Secretaries of other Departments are appointed by the Governor-General, who acts on the advice of the Prime Minister, who acts on the advice of the Secretary of PM&C.

Department Secretaries are appointed for a specific term, but a new appointment can override an old one at any point, allowing the Prime Minister to fire any Department Secretary for no reason, for political or performance reason, or any reason not forbidden by discrimination legislation.