Paternity leave and pay: How does the UK measure up to the rest of the world?

Author: Rocio Carracedo Lopez

For new fathers, taking some time off work to spend quality time and bond with their newborn is the number one priority - but they do not always enjoy generous statutory entitlements to do so. In fact, some countries do not provide specific leave for fathers at all. How does the UK's offering compare to global norms?

Paternity leave can be defined as a leave of absence from work granted to employed fathers (and sometimes non-birthing spouses or partners) for the birth of a child. It is independent of the mother's rights and often taken in parallel with other statutory leave entitlements (eg parental leave).

Which countries do not offer paternity leave?

Many countries lack statutory national provisions granting paid paternity leave.

In Germany, mothers who give birth are entitled to 14 weeks of statutory maternity leave but there is no paternity leave. However, in light of the EU Directive on Work-Life Balance for Parents and Carers (2019/1158/EU), the German government is planning to introduce two weeks of paid "partner leave" for the non-birthing parent in 2024.

Is the UK lagging behind in its paternity leave policy? 

In the UK, qualifying employees are entitled to take paternity leave of either one week or two consecutive weeks, or as two non-consecutive weeks. This is significantly less than the entitlements in some European countries, including Spain (16 weeks) and France (25 days of paternity leave plus the three days of paid leave to which all employees are entitled on the birth of a child).

Each country's legislation expresses paternity leave in days, weeks or months; calendar days or working days; and consecutive or non-consecutive days. In the UK, a week of paternity leave is the same duration as the employee's normal working week, meaning that for a full-time employee, one week may be five days. But if they are contracted to work four days per week, one week is four days and so on. These differences make comparisons difficult. However, for our purposes, the bar chart below represents paternity leave in days. 

In terms of pay, countries that offer a few days or a week or two of leave generally tend to offer full pay, but under UK statutory paternity pay rules, employees receive £184.03 (or 90% of the employee's average weekly earnings if this figure is less than £184.03). In March 2024, research from Pregnant Then Screwed, in partnership with Women In Data®, showed that around 70% of fathers who only used a portion of their paternity leave entitlement attributed cost as the reason for not taking their full entitlement. Employers may offer an enhanced pay rate, but the research found that fewer than 30% of fathers were able to access enhanced paternity pay around the birth of their most recent child.

Countries that offer longer periods of leave tend to provide reduced pay. In Belgium, an employee receives normal pay from their employer for the first three days of leave and a state benefit set at 82% of normal gross pay (up to a ceiling) for the remaining leave. Interestingly, Spain defies this trend as employees are entitled to a state allowance equivalent to 100% of the employee's social security contribution base (the amount of earnings that is subject to social security contributions) for the full 16 weeks of leave.

How does the UK's parental leave policy compare with those of other countries?

Some countries offer parental leave in addition to or in lieu of paternity leave. Parental leave is generally considered a family entitlement rather than an individual entitlement. In both EU and UK law, parental leave is distinct from maternity and paternity leave, but in some countries, the law does not distinguish between maternity, paternity and parental leave and adopts a gender-neutral approach.

To encourage fathers to take leave, some countries assign leave exclusively to them. In Denmark, both parents are entitled to nine weeks of earmarked parental leave, which is allocated to a specific parent and may not be transferred to the other parent. If a parent chooses not to take such leave, it will lapse. However, in other countries, such as Australia, parental leave is fully flexible and shareable between eligible working parents.

On the face of it, the UK's parental leave scheme may seem generous. Qualifying employees are entitled to take shared parental leave (SPL), whereby parents can share up to 50 weeks of parental leave in the year following their child's birth or adoption where the mother cuts maternity leave short; and a total of up to 18 weeks' "ordinary" parental leave in the period up until the child's 18th birthday.

However, looking at SPL in more depth, it involves the mother giving up part of her leave to transfer it to the father, and so it does not provide an individual entitlement. It is aimed at providing parents with greater flexibility over how to share childcare, which can create challenges for employers that may need to provide cover for short periods of time. Even though SPL has been up and running for close to a decade, it is still riddled with complexities. These factors have led to a very low take-up rate - only 5% of employee fathers are taking SPL following the birth or adoption of their child.

As with paternity leave, employees on SPL are on reduced pay. Ordinary parental leave is unpaid. The UK's position is a far cry from that in Japan, where employees are entitled to 12 months of leave and receive a benefit from the parental leave scheme, set at 67% of their wages for the first 180 days and 50% thereafter; or in Sweden, where the total entitlement is set at 480 days per child and each parent is entitled to 240 days of benefit.

How can global employers support fathers and second parents? 

For global employers, generous family-friendly policies can be essential tools to attract global talent, retain key staff and close the gender pay gap.

Global HR teams need to understand and comply with the minimum requirements for paternity and parental leave in all countries that they operate in. Employers could take a country-by-country approach to employee family-friendly rights, whereby the terms and conditions offered to employees will depend on local laws, HR practice and applicable collective agreements. Alternatively, multinational employers may wish to harmonise their approach and develop a global parental leave policy, applicable regardless of location. Whatever the approach, there should be clear policies in place outlining all the rules regarding eligibility, notice, and pay and benefits during leave.

Even where legislation is in place, there is no guarantee that employees will take the leave. Finding global data about the take-up for leave is notoriously difficult but there may be a number of reasons behind a low take-up including cultural gender norms, low pay, barriers due to how legislation dictates leave should be taken (eg in blocks rather than in days) and the availability of affordable childcare. Employers should encourage a culture of taking leave, think about their wellbeing programmes that can assist fathers (eg employee assistance programmes), and pre-empt possible roadblocks that may prevent employees from taking leave.