Maternity and Paternity

How Does the UK Fare vs. Europe and the World
26 March 2024 by
Maternity and Paternity
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As the world celebrated International Women's Day on 8 March 2024 and the UK celebrated Mother's Day on 10 March 2024, it is imperative to reflect on the state of maternity pay—a cornerstone of women's rights and social welfare.   

In the United Kingdom, the discourse surrounding statutory maternity pay often veers towards claims of generosity and adequacy. However, recent revelations challenge this narrative, exposing the stark realities faced by working mothers. This article aims to dissect the myths surrounding UK maternity pay, comparing it with international standards and advocating for meaningful reform to ensure equitable support for all mothers.

In response to mounting criticism, the Department of Work and Pensions (DWP) defended the UK's maternity system, citing provisions for up to 39 weeks of guaranteed pay—a claim refuted by advocacy groups. 

Despite government assertions touting the UK's system as one of the most generous globally, the reality paints a starkly different picture. The truth is far from the government's narrative. While the UK ostensibly offers 52 weeks of maternity leave, the reality is bleak for many working women. Initial maternity pay at 90% of earnings lasts for only six weeks, followed by 33 weeks at a low flat rate of £184.03 per week, funded by the Government. The final 13 weeks are unpaid, leaving mothers vulnerable to financial strain during a critical period. Fathers only get two weeks of Paternity Pay at the statutory rate of £184.03 per week. 

Maternity leave is a cornerstone of employee rights across Europe the world, ensuring support and protection for working mothers during a crucial life stage.

European countries uphold the rights of working mothers through directives like the Maternity Leave Directive (1992) and the Parental Leave Directive (2010). Maternity leave typically lasts a minimum of 14 weeks in Europe, with variations in duration and compensation. Eligibility criteria often include work hours or paid social security contributions.

Comparisons with the UK: The UK offers 52 weeks of statutory maternity leave, with SMP provided for up to 39 weeks. In contrast, European countries exhibit diverse approaches to maternity leave. For example, countries like Austria and Belgium offer extended leave periods, with maternity allowances based on earnings. Luxembourg provides 20 weeks of maternity leave, with compensation provided by the National Health Fund.


Countries with the Highest Rates of Maternity Pay

Poland:

  • Maternity Leave Duration: Up to 52 weeks of leave, made up of 20 weeks Maternity Leave and 32 Parental Leave. 
  • Maternity Pay:  100% of average earnings for the 12 months before the birth, with no upper limit on payments for the 20 weeks Maternity Leave and the first 6 weeks of Parental Leave, followed by 60%  for the remaining 26 weeks Parental Leave, or 80% of average earnings for the 12 months before the birth, with no upper limit on payments for both 20 weeks Maternity Leave and the immediately following 32 weeks Parental Leave.
  • Paternity Pay: 2 weeks Paternity Leave paid at 100 % of average earnings for the 12 months before the birth, with no upper limit on payments. 
  • Parental Leave can be taken by both the mother and the father.  

Slovenia:

  • Maternity Leave Duration: Up to 105 calendar days of maternity leave, followed by 130 days Parental Leave. The mother can move 100 of these days to the father.
  • Maternity Pay: 100% of the average base.
  • Paternity Leave and Pay: 30 calendar days paid at 100% of the average base, followed by 130 days Parental Leave, which can all be moved to the mother.
  • Parental Pay: 100% of the average base.

Estonia:

  • Maternity Leave Duration: Up to  100 consecutive calendar days of Maternity Leave
  • Maternity Pay: 100% of average earnings, covered by the Social Insurance Board
  • Paternity Leave and Pay: Up to 30 calendar days at 100% of average earnings

Spain:

  • Maternity Leave Duration: 16 weeks ( 102 days) to increase in 2024 to 20 weeks
  • Maternity Pay: 100% of base salary up to €4,070 per month, paid by the social security system

Russia:

  • Maternity Leave Duration: 140 days of Maternity Leave 
  • Maternity Pay: Women receive their full salary during maternity leave, covered by social insurance funds
  • Paternity Leave and Pay: Paid Paternity Leave is not a statutory right of employees in Russia. However, an employee who has become a father is eligible for up to 5 unpaid days of Paternity Leave.

Brazil:

  • Maternity Leave Duration: 120 days of Maternity Leave (extended to 180 days for some professions)
  • Maternity Pay: 100% of regular pay, without a cap, covered by social security .
  • Paternity Leave and Pay : 5 days paid at 100% of regular pay

China:

  • Maternity Leave Duration: 98 days of Maternity Leave 
  • Maternity Pay: Women receive full pay during Maternity Leave, covered by social insurance funds.
  • Paternity Leave and Pay 

India:

  • Maternity Leave Duration: 26 weeks of Maternity Leave
  • Maternity Pay: Women receive full pay during Maternity Leave
  • Paternity Leave and Pay: 

Italy:

  • Maternity Leave Duration: 20 weeks of Maternity Leave
  • Maternity Pay: 80% of earnings, potentially 100% if covered by collective bargaining agreement
  • Paternity Leave and Pay 

New Zealand: 

  • Maternity Leave Duration: up to 26 weeks of Primary Carer Leave ( replaced Maternity Leave)  followed by 26 weeks Extended Unpaid Parental Leave
  • Parental Leave Pay:  the lesser of the two: either 100% of average earnings  or NZ$ 712.17 per week 
  • Partner Leave and Pay: 2 weeks unpaid Partner's Leave ; allowed to take some of the Primary Carer's remaining Extended Parental Leave.  

Romania:

  • Maternity Leave Duration: 126 days of paid Maternity Leave
  • Maternity Pay: 85% of the average wage for the prior six months
  • Paternity Leave and Pay:

Norway:

  • Maternity Leave Duration: Up to 49 weeks of Paid Parental Leave
  • Parental Pay: Varies, but up to 80% of salary covered by National Security
  • Paternity Leave and Pay:

Slovakia:

  • Maternity Leave Duration: 34 weeks of Maternity Leave
  • Maternity Pay: Up to 75% of average earnings, funded by social insurance
  • Paternity Leave and Pay:

Czech Republic:

  • Maternity Leave Duration: 28 weeks of Maternity Leave
  • Pay: 70% of typical earnings, paid by the Social Security Administration
  • Paternity Leave and Pay

Hungary:

  • Maternity Leave Duration: 24 weeks of Maternity Leave
  • Maternity Pay: 70% of the daily average wage
  • Paternity Leave and Pay

Australia: 

  • Maternity Leave Duration: up to 18 weeks of Paid Parental Leave 
  • Parental Leave Pay: national minimum wage rate:   AUD 772.60 per week
  • Paternity Pay 

Canada: 

  • Maternity Leave Duration: up to 18 months of combined Maternity and Parental leave
  • Maternity Pay: 55 % of average weekly earnings.
  • Paternity Leave and Pay

Japan: 

  • Maternity Leave Duration: up to 14 weeks of Maternity Leave 
  • Maternity Pay:  67% of average earnings.
  • Paternity Leave and Pay:

South Korea: 

  • Provides up to 90 days of maternity leave with benefits at 40-100% of earnings.

South Africa: 

  • Maternity Leave Duration: up to 17.32 weeks of Maternity Leave 
  • Maternity Pay:  66% of average earnings. 
  • Paternity Leave and Pay 


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