A new international review of leave policies for parents shows the statutory offer in the UK is less generous than that of other European counties.
The ‘13th International Review of Leave Policies and Related Research 2017’, which compares maternity, paternity and parental leave policies across 42 countries, shows the UK provides the longest period of statutory maternity leave, along with Bulgaria, at 12 months. However, the UK and Ireland are the only European countries to pay for just part of the leave, at either a flat rate (income-related) or less than 66 per cent of earnings for all or most of the period.
In comparison, 21 European countries pay for all or most of the statutory period at 66 per cent of earnings or more – although in Germany this is for public sector employees only. However, the majority do not offer the same length of leave as the UK.
The review, which is carried out annually, also reveals that the UK’s parental leave policy is less generous than other countries. The UK provides four months, the minimum amount that EU member states must provide, but the leave is unpaid and there are restrictions on how much time parents can take off per year.
In comparison, 29 of the countries in the review that have a parental leave policy provide some form of payment.
Co-author of the review Peter Moss, emeritus professor of early childhood provision at University College London’s Institute of Education, told Nursery World, ‘The UK has a combination of a strangely configured and weak leave system.
‘It continues to strike me how badly developed the situation is in this country. The UK has a bizarre system of long and badly paid maternity leave and little attention is paid to parental leave.
‘We languish at the bottom of the European countries.’
Statutory maternity leave
Of all the 42 countries in the study, seven do not have a statutory, designated and paid maternity leave entitlement. The United States makes no provision nationally for paid leave for women at the time of pregnancy and childbirth, although the possibility of unpaid ‘family and medical leave’ exists for mothers working for employers with 50 or more staff. The other six countries – Australia, Iceland, New Zealand, Norway, Portugal and Sweden – provide paid leave that women may take at and around childbirth.
The review shows that the traditional concept of a maternity leave intended only for women, linked to pregnancy and childbirth and the first months of motherhood, treated as a health and welfare measure, remains the most common leave policy.
However, it finds an emerging trend away from the idea of maternity leave – either towards a birth-related leave for women, which can be transferred at least in part to fathers, or towards dropping maternity leave altogether in favour of a generic parental leave, usually with periods designated for mothers only and fathers only.
For instance, Iceland offers nine months’ parental leave, three months each for the mother and father and a further three months for the parents to divide as they choose – the only recognition of childbirth is the obligation for women to take two weeks leave after birth, with the possibility of an extended leave if a woman has suffered complications at or after giving birth.
Similar to the UK, mothers in the Czech Republic, Croatia, Israel and Spain can transfer part of their maternity leave to the father. According to the review, maternity leave can be transferred to fathers in some other countries, but only in extreme circumstances.
Statutory paternity leave
The review defines paternity leave as a ‘short period immediately after the birth that is only available to fathers (or in some countries also to same-sex partners) and is in addition to parental leave’.
It finds that 29 of the 42 countries have a statutory and designated paternity leave, plus the province of Quebec in Canada where fathers can take up to five weeks’ paid leave.
Paternity leave is generally paid, and mostly at a high-earnings-related level for the duration of leave.
The UK provides up to two weeks, paid at the lower of paternity rate of 90 per cent of earnings. In Luxembourg and South Africa, fathers can use another type of leave, ‘leave due to extraordinary circumstances’ or ‘family responsibility’ leave, at the time of the birth of their child, but a separate paternity leave does not exist.
Statutory parental leave
Other than countries in the EU, which must provide at least four months’ parental leave per parent, nine provide parental leave. The exceptions are Brazil, China, Mexico, South Africa, Switzerland, the US and Uruguay.
Six countries – Australia, Iceland, New Zealand, Norway, Portugal and Sweden – have parental leave that ‘subsumes’ either maternity leave or maternity and paternity leave, although periods of parental leave may be for mothers or fathers only.
The review finds that countries broadly divide into those where the total length of parental leave available is less than 15 months, and those where continuous leave is available for up to three years or more. Some countries supplement parental leave with childcare leave, extending the period available.
In addition to parental and childcare leave, only Belgium provides a third type of leave – an entitlement to a break from employment for any reason, including, but not confined to, childcare, paid at a flat rate under certain conditions.
This entitlement, which Professor Moss said should be introduced in the UK, enables parents to take one year’s full-time leave (or 24 months’ half-time leave, or 60 months’ one-fifth-time leave) that could be extended up to five years by collective agreement negotiated at sectoral or company level.
Early childhood education and care
The review also looks at the relationship between leave and early childhood education and care (ECEC).
It shows that more than half of the countries, 25, have an entitlement to an ECEC service, but in most cases (18 countries) this is only from three years.
Only in seven countries is there an entitlement before three years of age – Belgium, Denmark, Finland, Malta, Norway, Slovenia and Sweden. The review says it is only in these countries where policies are designed to ensure no gap exists between the end of well-paid leave and the start of an ECEC entitlement. Elsewhere, the gap is from 12 to 66 months.
Commenting on the gap between leave and ECEC in the UK, Professor Moss said, ‘The UK needs to focus more on the relationship between the two.
‘In this country, there is a big gap between leave and early childhood education and care. This is probably because we don’t look at the two together as one is controlled by the Department for Business, Energy and Industrial Strategy, and the other, the Department for Education. We rarely bring children into the equation. Maternity leave is seen as an employment thing and for women.’
He added, ‘The Nordic countries are the best for bringing the two together. We need to look at the design of the leave system and ECEC, how the two systems fit together – the Nordic countries have got that spot on.’
A Government spokesperson said, ‘The UK’s maternity leave system is one of the most generous in the world, with most mothers entitled to up to 39 weeks of guaranteed pay – nearly three times the minimum EU requirement.
‘We recognise that parents should have a choice when it comes to balancing work and childcare, which is why eligible working parents can share up to 50 weeks of shared parental leave, around 20 million people can request flexible working and we are doubling the amount of free childcare for working parents of three- and four-year-olds.’
-reprinted from Nursery World