PARENTAL LEAVE AND CARERS LEAVE: INTERNATIONAL PROVISION AND RESEARCH
Appendix 7: The relationship between paid parental leave and unpaid leave for parents to care for children and others, in countries where both are available
|
Total statutory post-natal leave (paid mths in brackets), entitlement basis, and long leave opp. |
Statutory entitlement leave to care for sick child |
Leave to care for family member |
|
|---|---|---|---|
| Australia |
12 mths ( - ) Family No long leave for childcare or career break |
- No statutory entitlement, but employees have industrial right to take 5 days p.a. of personal sick leave | |
| Austria |
24 mths (24)* Family Non-stat. Employer-employee-agreed unpaid leave of 6-12 mths for any reason |
Paid - high; 0.5 mths | Paid - full; 1 week p.a; + 6 mths to care for seriously ill person - means- tested with benefit payments if low-income |
| Belgium |
9.5 mths (9.5) Individual For eligible workers 1-5 years of leave with duration, timing and pay all based on a complex time credit system |
Unpaid; 0.5 mths |
10 days unpaid p.a. for urgent reason incl. family care; access to FT leave for 1-12 mths (up to 24 mths for PT) for serious illness in family, but in blocks of 3 mths. Priority given for the long leave (see column 1) for workers with severely ill family members |
| Canada |
12 mths (11.5) Family No long leave for childcare or career break |
- No statutory entitlements re children, but 3 jurisdictions have 3-5 unpaid days per year for family care; 9 have compassionate care provisions to care for family member when death is likely within 26 wks. Benefit of up to 6 weeks can be claimed via employment insurance for those eligible. Can also be used by parents, even after 52 weeks since the birth, and no other leave left | |
| Czech Republic |
36 mths (36) Individual No long leave for childcare or career break |
No general statutory entitlement for sick children, but all employees eligible for benefit if they care for a sick relative at home. Leave must be taken in blocks of 9 days but no limit on frequency | |
| Denmark |
10.5 mths (10.5) Family No long leave for childcare or career break |
- no statutory entitlement re care for children, but all employees eligible for a care benefit if they care for a terminally ill relative or close friend at home | |
| Estonia |
36 mths (36) Family No long carers' leave |
Childcare leave 2 wks per year re children under 14 plus 1 day per mth for parents with disabled child, and extra 3-6 days holiday p.a. for families with dep children | |
| Finland |
36 mths (36) Home care leave can be taken after parental leave i.e. from child's 3rd birthday, paid by basic home care allowance plus means-tested top-up, plus some municipal supplements |
- No stat. provision, 2-4 days at a time available re children under 10 - often full pay but depends on collective agreement | In addition to home care leave, paid 'Partial care leave' available as a form of flexible working, until around 8 yrs - partial home care allowance available. Could be used for seriously ill child; no information on other dependants |
| France |
36 mths (36) * (a) Family No long leave for childcare or career break |
- Unpaid; 3 days p.a. per parent | Leave to care for sick child can be extended if child is seriously ill or disabled, and parent can receive flat-rate benefit |
| Germany |
36 mths (24) * (b) Family No long leave for childcare or career break |
No statutory provision, but up to 10 days p.a. paid - high, for children under 12, up to 25 days max per family. No information re other dependants | |
| Greece |
9mths (2) Individual Longer leave for childcare part of flexible working arrangements |
2 wks unpaid leave per year for employee with child under 14 | |
| Hungary |
36 mths (36) (c) Family; Insured parents paid; Uninsured parents unpaid; Long leave opportunity for childrearing only, but paid at basic benefit level till child is 8. |
Paid - high. Entitlement to leave to care for dependants is unlimited if child is under 1; up to 84 days per child p.a. for age 12-35 mths; 42 days for 36-71 mths; and 14 days 6-14 years. Paid at 70% of earnings and includes self-employed. Lone parents get double entitlement, as do parents of twins. No info on other dependants | |
| Iceland |
9 mths (9) Family + Individual Each parent can take 3 mths unpaid leave p.a. till child is 8 yrs for childcare, or for career break. |
Parental leave can be extended by up to 3 mths if child seriously ill. No other separate leave to care for dependants | |
| Ireland |
12 mths (4) Individual No long leave for childcare or career break |
Paid - high i.e. 3 days in any 12 consecutive mths up to max 5 days in any 36 consecutive mths; but employees with 12 mths continuous service can take max 65 weeks unpaid leave (Carers' Leave) to care FT for family dependant eg child with disability. Such employees may be eligible for means-tested Carers' Benefit | |
| Italy |
12.5 mths (12.5) (d) Individual No long leave for childcare or career break |
Unpaid leave for sick child unlimited for child under 3 yrs; + 5 days per parent for child 3-8 years | No information on leave to care for other dependants |
| Netherlands |
8.5 mths (2.5) Individual |
Paid - high - 70% of earnings, paid by employer; up to 10 days p.a. to care for sick child living at home, or a sick partner or parent. Strict conditions re need, and employer can refuse on serious business grounds. As well, leave for 'reasonable' time (a few days or hours) at 100% of earnings to attend to urgent matters at home (death, broken water pipe etc) | |
| Norway |
11.5 mths (11.5) Family + Individual Each parent has right to one year of unpaid leave, after parental leave. If for children 12-36 mths, full cash benefit is paid if child does not attend childcare; partial benefit if child attends part-time |
Paid - high; 10 days per parent if one child under 12; 15 days if 2 + children. More for chronically sick child, to age 18 yrs and paid at sickness benefit rate | No information on leave to care for other dependants |
| Portugal |
11.5 mths (5.5) Individual Plus leave for 2 years (or 3 for 3+ children, or 4 years if a child is disabled) for childcare or career break, for one parent only, with all employment rights eg holidays, and return to work protected |
Paid at 65% of minimum wage - Family entitlement to up to 30 days p.a. for sick child under 10. No age limit if child is chronically ill or disabled: payment at lower benefit rate. | Up to 15 days per year to care for a spouse, older child or co-resident elderly relative, increased by 1 day for every second and subsequent child |
| Slovenia |
12 mths (12) Individual No long leave for childcare or career break |
Insured workers entitled to 7 days' leave to care for immediate co-resident family member who is ill, paid at 80% of avge. earnings over preceding 12 mths. 15 working days maybe taken re severe illness; or 14 or 30 in more serious cases, up to 6mths for extreme situations. Minimum payment level is the guaranteed wage. | |
| Spain |
36 mths (3.5) Individual No long leave for childcare or career break |
2 days' leave per worker (paid by employer) to care for sick child or other family reason eg death of close relative; up to 4 days if travel involved. As well, each worker (not just parents) may take up to one year of unpaid leave, or working hours reduced by 1/3 to ½, to care for close relative re illness, accident or old age. | |
| Sweden |
(e) 16 mths (13 high + 3 mths lower rate), plus 18mths unpaid Family + Individual As well, qualifying employees can apply to take 3-12 mths leave for childcare or career break at 85% of UB up to earnings-related max |
Family entitlement to 60 days per child under 12 p.a. paid at 80% of earnings, and for children 12-15 with Dr certificate. | No information about leave to care for others |
| United Kingdom |
18 mths (6, but intention stated to extend paid amt to 12 mths by 09-10) Individual No long leave for childcare or career break |
Unpaid parental leave is extended to 18 weeks for parents of disabled children, to take any time before child is 18 (otherwise 13 wks for other parents) Employees can take 'reasonable' amount of unpaid time off to deal with emergencies eg family illness, injury; disruption of childcare arrangements; unexpected incident re child's school hours |
|
| United States |
No statutory right to leave, but FMLA (f) provides 12 weeks leave in each 12 mth period for birth and/or care of child up to 12 mths No long leave for childcare or career break |
The FMLA leave of 12 weeks per year is also available for care of seriously ill child, spouse or parent; or for serious medical condition of employee lasting more than 3 consecutive working days - i.e. it operates as personal sick leave as well as for caring for others | |
Source: data selected from Table 1 in Moss and O'Brien (2006) and country notes on Austria from Deven and Moss (2005)
Key:
* indicates that payment is made to all parents, whether or not they take leave
'high' indicates that the rate paid to all parents is more than 50% or earnings (usually up to a ceiling)
'low' indicates there is a statutory entitlement to leave with pay, but the rate is either a low flat rate; or earnings related at less than 50% of earnings; or not universal; or for less than the full period of leave
a - in France, only paid to parents with one child until 6 months after the end of maternity leave
b - in Germany, payment after maternity leave until child is 2 years is means tested
c - in Hungary, uninsured mothers can take unpaid maternity leave 168 days (paid for insured mothers), then insured parents receive 70% of earnings if on leave until child's 3rd birthday, then either parent can take leave at flat rate up till child is 8 in families with three children, or to 10 if child cannot attend school because of illness or disability (discretionary up to age 14).
d - in Italy, parental leave is 6 months per parents, but total leave per family cannot exceed 10 months
e - in Sweden, there is 480 (approx 16 mths) days paid leave per family, divided between individual and family entitlements; 390 days (approx 13 mths) at 90% of earnings and 90 days at a low flat rate; also each parent entitled to 18 months unpaid leave
f - the Family and Medical Leave Act is administered by the federal department for Labour. Note that employers with fewer than 50 employees are exempt.