There is no legal obligation for employers to provide a reference and in the case of gross misconduct it is not unusual for an employer to refuse to provide a reference. When providing a reference employers have a duty to take reasonable care that it is true, accurate, and fair. If your current or previous employer has provided a misleading reference, they may be liable for any economic loss you have suffered as a result of any negligent misstatement. Subject to the rules which restrict some employers (for example in the context of regulatory requirements), reference wording can usually be negotiated as part of an exit to assist with a smooth transition into your next role.