Introduction

For many people, caring responsibilities go far beyond those associated with parenting, and for some, do not coincide at all. It is not only young children who need care, and it is not only parents who provide it. A number of countries have now begun to make a separate category of carers' leave available, often on a paid basis.

To comply with EU's Directive on Parental Leave, all EU member states must provide at least three months leave per parent for childcare purposes, according to the EU Parental Leave Directive. It also gives all workers an entitlement to 'time off from work on grounds of force majeure for urgent family reasons in cases of sickness or accident making their immediate presence indispensable', but does not specify minimum requirements for length of time or payment.

The information for the 23 countries in the two major reports reviewed here includes two types of what could be termed carers' leave: the first is long leave for childcare or career break purposes, and the second is a separate provision of leave to care for family members. In this section, the separate provisions regarding leave to care for sick children, leave for 'childcare or career breaks', and leave to care for a family member (both paid and unpaid) will be discussed. The 23 countries include examples where each of these forms of leave is provided on a paid basis (some), as well as on an unpaid basis (most), as will be discussed below. In some countries, payment is available for childcare and career break leave, and most countries provide some paid leave for parents to care for sick children, usually less than 10 days per year.

Among the countries reviewed for this report, there is a strong theme of providing paid leave (rather than unpaid) to care for sick children, as well as to care for other relatives over a short duration (i.e. not more than a month). But it does not follow that if one type of leave provision is unpaid, then other leaves are also likely to be unpaid. In those countries where long leave to care for family relatives is unpaid, the provision is often combined with paid options of shorter leave to care for sick children or to attend to urgent family needs. In a few countries, the entitlement for leave to care for a sick child is merged with that to look after other family members, but mostly it is kept separate. Appendix 6 provides a quick reference to the various combinations.

Leave to care for sick children

The countries where paid leave for looking after sick children is provided by statute are listed in Appendix 1 and again in Appendix 5 where it is presented alongside other forms of leave to care for others. Most of the 23 countries are included in this list, except for Denmark, Finland, Iceland and the United States. The length of time varies from a day or two, up to around two weeks per year. Eligibility is usually based on the same employment-related (or other) rules that apply for other leaves provided in the same country - mostly having worked for a certain amount of time within a recent period.

Among the EU member states included in the two reports analysed here, six specify an entitlement to leave of 10 days or more per year to care for sick children (age range varies), and is paid in all but one. In the other states the leave is shorter or unspecified, and unpaid. Among the non-European states, Australia, and Canada have entitlements to paid leave to care for sick children.

As Appendix 5 shows, about half of the countries (13) reviewed for this report provide leave to care for sick children that is paid at the higher rate (i.e. over 50 percent of earnings). No countries provide this type of leave but paid at the lower level of less than 50 percent of earnings. Six countries provide unpaid leave to care for sick children, and the remaining five countries do not provide statutory leave for this purpose. This is not to say that such leave is therefore unavailable in those countries, since all or some of the provision may be arranged by employers. In eight countries, this leave can be used to care for other family members (five paid; three unpaid).

Leave for childcare and/or career break

A number of countries offer a period of longer leave (presumably job-protected, although this is not always made clear) for an extended period of childcare, or for a career break sought because of parenting responsibility. The countries where this type of longer leave for childcare or career break is provided by statute include Belgium and Greece (provided as part of flexible working arrangements), Finland, Hungary, Iceland (3 months per year per parent until child is 8), Norway, Portugal and Sweden. This type of leave is paid at the benefit rate in Finland, Hungary, Norway (if the child does not attend a publicly-funded childcare facility - otherwise unpaid) and in Sweden. The country notes in the original two reports do not confirm whether eligibility for the benefit-level payments depends on other eligibility criteria associated with the benefit system, or whether all parents taking this leave are eligible, although this later interpretation is implied.

Belgium provides paid leave but as part of a time-credit system with various constraints on eligibility, including a limitation on the percentage of employees in any one company that can be taking the leave at any one time. In Greece it is paid at full earnings where it is provided as part of flexible working, and is for a much shorter duration (almost four months) than in the other countries included here. The leave is unpaid in Iceland and Portugal. Details are provided in Appendix 5.

Paid carers' leave

A period of leave of between several months and a year or more to care for another family member such as a spouse, elderly relative, or an older child with a disability is provided on a paid basis in Austria, Belgium, Canada, Czech Republic, France, Ireland and Slovenia. Shorter leave is available in the Netherlands (10 days). In Denmark and Finland the duration of leave was unclear in the original material. Appendices 5 and 7 provide further information, but note that as information was not available for all 23 countries, this analysis cannot be regarded as complete. Payment is usually calculated at a benefit-level entitlement, although it is not clear whether other eligibility criteria for the benefit also apply (such as an income threshold).

Unpaid carers' leave

Instead of, or sometimes in addition to paid leave, a period of unpaid leave to care for family members is available in Canada (3-5 days in BC, NB and Q), Portugal (15 days) Spain (up to one year) and the United Kingdom (a few days only). Unfortunately the information provided in Deven and Moss (2005) and in Moss and O'Brien (2006) does not indicate the details of employment protection (if any) might be available for people on leave for childcare or career breaks, or caring for family members, whether paid or unpaid.

According to the information available, the only country with a long period of statutory, unpaid carers' leave is Spain (up to a year). No information is available on whether this leave must be taken in one block, or can be split into several blocks. The intention of the policy appears to be to extend to all employees the leave entitlement held by parents with young children, to workers with other care responsibilities. Public employees can extend the leave to care for a relative for up to three years. The country notes in Moss and O'Brien (2006) advise that such employees can work half-time for up to one month without loss of earnings in the case of a seriously ill first degree relative (child, partner or parent), and can also benefit from flexibility in working time as do parents of children up to 12 years. No information is available regarding the impact on employers of this leave. The information available states that take-up is low: in 2002 there were only 126 users of unpaid leave to care for adult dependants throughout the whole of Spain. But 538 employees in one region only (Catalonia) took a working time reduction with partial earning s compensation to care for dependent or disabled relatives. Moss and O'Brien consider that this result shows that paid leave or reduced working hours attract more use than does an unpaid entitlement.

The table at Appendix 7 presents data selected from Deven and Moss (2005) and Moss and O'Brien (2006) that contrasts total post-natal leave entitlements for parents with the amount of leave that can be taken to care for sick children. Unfortunately for this report, information on both care for children and care for other people was not included for many of the countries included in these publications, and is not readily available elsewhere.

The relationship between unpaid carers leave and paid parental leave in countries where both are available does not show any strong pattern of associations between provision of one type of leave and another. However, some countries merge the provision of extended leave to care for children (who may or may not be ill or disabled), with leave to care for family members. As Appendix 7 shows, these countries that merge the two types of statutory leave are: Canada, Czech Republic, Denmark, Finland, Ireland, Netherlands, Portugal, Slovenia, Spain and the United Kingdom (where 'a reasonable time' is available for emergency care of other relatives than children). Importantly, information on the care of relatives other than children was not available for Germany, Hungary, Italy, Norway, and Sweden. These omissions make impossible a useful analysis of the relationship between leave arrangements in those countries that merge entitlements to care for children and for other family members, and those that do not.

Of these counties, only Canada provides unpaid carers' leave in combination with paid parental leave. In Portugal, Spain and the United Kingdom, parental leave is also unpaid. However, in Portugal and Spain, maternity leave is paid at the higher rate (i.e. over 50 percent of earnings), and in the United Kingdom, the period of maternity leave is to be extended to nine months, again illustrating the difficulty of comparing provision of one type of leave with another, on an inter-country basis.

Impacts of paid carers' leave - take-up

No definitive analysis is possible to identify patterns of take-up of leave to care for others. The main reason why very few countries provided data for the two studies on uptake of short-term leave to care for sick children or other family members, is because employers are not necessarily obliged to provide it. Nevertheless, some data on take-up of carers' leave are available as follows:

Austria: contrary to the government's expectations, take-up of family hospice leave (i.e. for terminally ill people) has been low: in 2003, only 470 persons - no data is available on take-up of leave to care for other persons;

Netherlands: survey evidence showed that only a small proportion of people had made use of leave to care for other family members - short-term leave was used by nine percent of employees to care for a sick child, partner or parent, and emergency leave was used by five percent if employees - most people taking time off for an emergency took annual leave or leave accrued in lieu of pay. A small number (about five percent of cases) reported ill themselves to justify taking emergency leave. It is important to remember the Netherlands has a high proportion of part-time workers, both male and female. Reasons for not taking leave included no need, because the part-time hours permitted enough flexibility, and employment-related reasons such as not wanting to inconvenience colleagues, or work would not permit it;

Spain: take-up of unpaid leave is very low: only 126 persons in the whole of Spain in 2003;

United Kingdom: a 2002 survey found that only 10 percent of the approximately 55 percent of employees who knew about the entitlement, had used it.

No information on take-up was available for the other countries with a statutory carers' leave entitlement.

Further to the above information, it was estimated that in Hungary in 2003, the leave taken by parents to care for sick children accounted for 3% of all paid sick leave. All of these results suggest that few employees make extensive use of such entitlements.