The employment relationship did not end as happily as it had begun. After some discussions with the employer, the employee resigned. She then required the employer to formulate the following in the work reference:

”Ms. [...] is leaving our company at her own request on 31.12.2019, which we very much regret. We would like to thank Ms. [...] all the best and every success professionally and privately. ”

Both the Munich Labour Court and the Munich Regional Labor Court rejected this. According to the basic case law of the Federal Labour Court, employees have no general right to include a final formula in an employment reference. If anything, a good review simply justifies a thank-you and wishes formula with the content:

“We would like to thank you for the work you have done and wish you all the best for the future.”

A remorse is not common when the evaluation is only good.

Conclusion: If an employer does not regret that someone leaves, then he does not have to say anything to the contrary in the employment reference. He also doesn't have to thank or wish anything.