Maternity leave by country: how time off, pay and eligibility compare

Key takeaways

• A maternity-leave figure is useful only when it identifies the type of leave. Maternity protection, parental leave and home-care leave can sit in different legal schemes, and some countries include maternity provisions within parental leave rather than publish a separate paid maternity entitlement.
• Read paid weeks alongside the payment basis. In the OECD comparison, paid weeks mean weeks with at least some payment; its full-rate equivalent combines duration with the average payment rate for a model earner. Neither figure predicts a particular worker’s income.
• Protected time away from work and statutory pay can follow separate tracks. In the United Kingdom, Statutory Maternity Leave lasts up to 52 weeks, while Statutory Maternity Pay lasts up to 39 weeks for eligible employees.
• A federal US figure does not settle an individual case. Eligible workers may receive up to 12 weeks of unpaid, job-protected leave under the FMLA, while state programmes can provide paid leave.
• There is no defensible worldwide winner for the “longest” maternity leave. Bulgaria’s 58.6 paid maternity weeks is the highest maternity-only figure in the OECD/EU table based on April 2025 rules, so it is a result within that defined comparison.

What counts as maternity leave in a country comparison?

A country comparison is useful when it separates the legal right to time away from work from the benefit paid during that time. A headline number can otherwise combine different kinds of leave, different payment rules and different groups of workers. Start by identifying the leave category, then read duration, payment rate and eligibility as separate fields.

Maternity leave, parental leave and other time off

Maternity leave usually means leave connected with pregnancy and childbirth. It is not interchangeable with paternity leave, shared parental leave or home-care leave. The OECD distinguishes these categories because they answer different questions about who can take the leave and when.

In some countries, maternity protection sits within a broader parental-leave scheme instead of a standalone paid maternity benefit. A separate maternity figure can therefore look low or absent without describing the full family-leave framework. For a practical comparison, label the category before comparing its duration.

Protected weeks, paid weeks and full-rate equivalents

Protected leave and paid leave measure different things. Protected weeks describe the period in which a worker can be away from work under the relevant right; paid weeks describe the period for which at least some payment is available. A country can provide a longer protected absence than its statutory paid period.

Payment duration also does not reveal how much income a worker receives. OECD full-rate-equivalent weeks multiply paid duration by the average payment rate for its model earner. That makes a lower-rate, longer payment period easier to compare with a shorter period paid at a higher rate, but it is not a personal benefit estimate. The model assumes national average earnings, and some country rates use net income while others use gross income, so the figures cannot be read as a worker’s expected take-home pay.

What a country table can and cannot tell you

A well-labelled table identifies the statutory category, whether payment is included and whether duration is converted into a full-rate equivalent.

It cannot decide an individual entitlement. OECD national or federal figures leave out state and local alternatives, employer top-ups and actual take-up. Eligibility can also depend on worker status, service history, insurance and the governing system. Use a country row to frame the questions for a local check, then confirm the applicable leave right and benefit route for the worker concerned.

Maternity leave across countries at a glance

The figures below use the OECD’s maternity-only measure: paid maternity weeks under national or federal rules applicable in April 2025. They do not include state or local programmes, employer top-ups or actual take-up.

The ILO benchmark and OECD comparison

The International Labour Organization’s Maternity Protection Convention sets a 14-week maternity-leave standard, including six compulsory weeks after childbirth unless national arrangements provide otherwise. It is an international treaty standard, not an automatic entitlement in every country.

The OECD comparison covers OECD and EU countries and uses a consistent maternity-only category. That makes it a useful starting point for comparing statutory paid time, provided the result stays within that scope. It does not establish a worldwide ranking or replace the local eligibility rules that determine a person’s entitlement.

Paid maternity weeks in four countries

Country	Paid maternity leave	Scope of the figure
Germany	14.0 weeks	OECD maternity-only measure; national/federal rules in April 2025
Cyprus	22.0 weeks	OECD maternity-only measure; national/federal rules in April 2025
United Kingdom	39.0 weeks	OECD maternity-only measure; national/federal rules in April 2025
United States	0.0 weeks	OECD maternity-only measure at the federal level; state and local alternatives are outside this figure

The table compares paid duration, not a worker’s likely income. For example, the OECD’s UK model reports a 29.9% average replacement rate and 11.7 full-rate-equivalent maternity weeks for an average earner. The full-rate-equivalent calculation helps compare duration with payment level, but it is not a personal payment forecast.

Which countries have the longest or most generous leave?

“Longest” needs a defined measure. In the OECD/EU table using paid maternity weeks, Bulgaria has the highest maternity-only figure at 58.6 weeks under the April 2025 rules. That answer cannot be expanded into a worldwide claim, and it does not establish which country offers the most generous overall family-leave package.

Generosity may depend on the payment rate, eligibility, job protection, parental leave available to either parent and employer benefits outside the statutory scheme. Compare those elements separately before using a duration figure to make a policy or staffing decision.

What a zero US federal figure means

The United States shows 0.0 paid maternity weeks in the OECD’s federal measure. It does not follow that every US worker has no paid leave: state programmes can provide paid family leave, and employer policies may add support outside the statutory comparison.

For a distributed team, a low or zero national figure calls for a check of the relevant state or local programme, the employment relationship and the employer policy.

How leave works in different countries

Country rules differ in protected time, eligibility, payment and the reach of a national headline figure.

United States: federal protection and state variation

For eligible US workers, the Family and Medical Leave Act provides up to 12 weeks of unpaid, job-protected leave in a year and requires group health benefits to be maintained. It is a federal protection rule, not a federal paid maternity-leave benefit.

There is no general federal guarantee of paid family and medical leave for private-sector workers. State programmes can provide paid leave, so a US case needs a state-level check alongside the FMLA question. A federal comparison row with zero paid maternity weeks describes that national baseline; it does not settle the support available to every worker.

United Kingdom: leave and pay follow different rules

UK Statutory Maternity Leave can last up to 52 weeks: 26 weeks of ordinary leave followed by 26 weeks of additional leave. Statutory Maternity Pay can last up to 39 weeks for someone who meets its separate conditions. The difference between those durations is why protected absence and paid time should be planned on separate tracks.

Leave notice and the SMP claim also have different deadlines and proof requirements. Pregnancy proof belongs to the SMP process, not the leave notice.

Germany: maternity protection and later parental leave

Germany’s normal maternity-protection period begins six weeks before the expected birth and ends eight weeks after the birth. Maternity benefits depend on the worker’s situation, health-insurance status and the protection period, so the time window alone does not determine the payment route.

Germany also has Elternzeit, a separate unpaid parental-leave right for employed mothers and fathers that can last up to three years per child. Elterngeld is a separate possible payment. Treating either of those parental arrangements as an extension of maternity protection would blur the rights and benefits a worker needs to check.

Australia: parental leave and payment are separate

Eligible Australian employees may take up to 12 months of unpaid parental leave, subject to service and employment-status tests. Regular casual employees may also qualify after 12 months of regular and systematic work when there is a reasonable expectation that the work will continue.

Government Parental Leave Pay is a separate route. From July 2026, eligible families may share up to 26 weeks of that payment. An employer can also provide parental-leave payments through an agreement, contract or workplace policy. For planning, identify the leave right, the government payment and any employer top-up as distinct parts of the arrangement.

Who qualifies for leave and maternity benefits?

Eligibility has to be tested twice: once for the right to leave and again for the payment attached to it. Those tests may use different rules, and a country comparison cannot tell you whether a particular worker passes either one.

Employment status and service or contribution tests

Start by establishing the worker’s legal status. In the UK, statutory maternity leave is available to employees who give the required notice regardless of how long they have worked, their hours or their earnings. Statutory Maternity Pay has a separate service test: 26 continuous weeks with the employer by the qualifying week. SMP also has an earnings test. Confirm the current weekly threshold with HMRC before deciding whether the worker qualifies.

Australian rules show why status needs a close reading. Eligible employees can take unpaid parental leave subject to service and status tests. Regular casual employees may qualify after 12 months of regular and systematic work when they have a reasonable expectation of continuing work.

Cross-border work and the governing system

For work within the EU social-security coordination area, the basic starting rule is the country where the person actually works, regardless of where they live or where their employer is based. That starting point directs the benefits and social-security check; it does not answer every cross-border case by itself.

Posting and work in multiple countries are exceptions to the basic rule, and the relevant social-security institutions assess which system applies. A distributed employer should document where the work is performed, identify the relationship and obtain local advice before promising a leave benefit across borders.

What to check when the standard benefit does not apply

Failing a pay test does not always remove the leave right. In the UK, a worker who cannot receive Statutory Maternity Pay may be able to claim Maternity Allowance, including in some self-employed cases. Leave, statutory pay and alternative support should therefore be checked as separate routes.

Use a short case record for each worker: employment status, work location, applicable social-insurance system, service or contribution history, notice deadline and evidence needed for the claim. That record gives HR, finance and the worker a shared basis for the local eligibility decision.

Who pays during maternity leave?

The source of a maternity-related payment can differ from the employer’s final cost. Statutory schemes, employer reimbursement rules and voluntary top-ups should be recorded separately so that finance does not treat a worker’s benefit as a single, uniform expense.

Statutory benefit, employer funding and reimbursement

In the UK, employers can reclaim statutory maternity-pay costs through HMRC. For 2026–27, the recovery rate is 92% for employers whose prior-year Class 1 National Insurance liability exceeds £45,000 and 109% for those at or below that threshold. Those percentages describe employer recovery, not the employee’s wage-replacement rate.

Australia separates the government Parental Leave Pay route from the employment right to unpaid parental leave. Eligible families may share up to 26 weeks of government Parental Leave Pay from July 2026. The funding question therefore starts with the applicable statutory scheme and then asks whether the employer has made a separate commitment.

Employer top-ups and the worker's likely income

An employer can provide parental-leave payments through an agreement, employment contract or workplace policy in addition to Australia’s government payment. That top-up may be material to a worker’s income, but it is not part of every statutory comparison.

The OECD’s country figures exclude employer-provided top-ups, and its payment-rate model is based on national average earnings rather than an individual employee’s pay. Use the statutory benefit to identify the legal baseline, then read the contract, policy and any applicable cap before forecasting income or approving leave coverage.

What must happen before, during and after leave?

Leave administration works best when the leave right and the payment claim have separate owners, dates and records. A single “maternity leave” task can hide different notice, proof and response requirements.

Notice, evidence and benefit claims

For UK maternity leave, the employee should notify the employer at least 15 weeks before the due date. The employer then confirms the leave dates within 28 days. Statutory Maternity Pay follows a separate route: the employee gives at least 28 days’ notice and pregnancy proof, and the employer confirms the payment amount and dates within 28 days.

Pregnancy proof belongs to the SMP claim, not the maternity-leave notice. Keep those two requests distinct in the employee checklist and assign each response deadline to a named owner.

Job protection, coverage and return to work

Before leave begins, agree on the handover, the point of contact during absence and the return conversation. In Australia, an employee returning from unpaid parental leave has a right to their previous position or, if it no longer exists, the nearest suitable available role with the same status and pay.

Don’t be afraid to have conversations before an employee returns to work and don’t be scared to ask questions

— Catriona Spendlicek, HR Operations Manager, Quensh

The return plan should therefore address the role, any changes since leave began and the employee’s route back into the team before a start date is assumed.

Records and rule updates for distributed teams

UK employers must keep the specified SMP proof, payment and recovery records for three years after the end of the relevant tax year. Treat the evidence, claim dates, payment confirmation and recovery record as one case file rather than scattering them across HR, finance and payroll systems.

For each country where the team operates, keep the current notice path, eligibility check and record-retention rule with the leave policy. When a local rule or benefit process changes, update the checklist and the owner responsible for applying it before the next case reaches a deadline.

How should a global employer set its policy?

A global policy should begin with the rights that apply in each country, then state any voluntary support the employer adds. A single global promise cannot replace local leave, benefit, notice and return-to-work rules.

Start with local rights, then choose a voluntary floor

Separate the legal minimum from the employer’s own policy. The local right determines the statutory leave and benefit route; a voluntary floor can add a defined paid-leave commitment for eligible employees where the employer chooses to provide one. It should preserve any higher local benefit rather than reduce it to the global floor.

We wanted to ensure eligible employees receive the same paid leave benefit regardless of their geographic location, so we created a global core minimum standard.

— Tracy Layney, Chief Human Resources Officer, Levi Strauss & Co.

This is a policy-design example, not evidence that one leave standard suits every jurisdiction. Define the floor’s eligibility, payment basis and relationship to local benefits before presenting it to the workforce.

Keep eligibility, claims and exceptions country-specific

The policy should identify what remains local: worker status, service or contribution tests, the applicable social-insurance system, notice deadlines, proof and claim administration. Cross-border work, posting and multi-country arrangements require a separate governing-system check rather than an assumption based on the employer’s location.

We found it critical to work alongside local HR teams to receive their input in order to understand the cultural and regulatory differences between countries.

— Mary Alice Vuicic, Chief People Officer, Thomson Reuters

Give local HR, legal and payroll owners a clear route to raise an exception before the employee receives a commitment. That keeps a global policy readable while allowing the underlying country process to remain accurate.

Plan team coverage and a supported return

Build the operational plan around the person’s absence and return: handover, temporary coverage, contact boundaries, the return role and the owner of each country-specific step. The NY/PA employer study found a first-year improvement in surveyed firms’ reported ease of handling absences after paid family leave, but it found no significant second-year improvement or employee-performance effect. Its results concern small and mid-sized firms in that US setting and do not predict the outcome of a global maternity policy.

The study cannot establish a return on investment for a global policy. Managers, finance and the employee still need a shared coverage and return plan.

Frequently asked questions

Which country has the longest maternity leave?

Within the OECD/EU table of paid maternity weeks under April 2025 rules, Bulgaria has the largest maternity-only figure at 58.6 weeks. That is not a worldwide result, and it does not compare mixed maternity and parental-leave totals. Payment rates, eligibility and job protection still need separate comparison before calling one policy more generous.

Does the United States have paid maternity leave?

The United States has no general federal guarantee of paid family and medical leave for private-sector workers. Eligible workers may receive up to 12 weeks of unpaid, job-protected leave under the FMLA, while state programmes can provide paid leave. Check the worker’s state and the employer policy before answering a specific case.

What is the global minimum for maternity leave?

ILO Convention No. 183 sets a 14-week maternity-leave standard, including six compulsory weeks after childbirth unless nationally agreed otherwise. It is a treaty standard, not an automatic entitlement in every country. The applicable national law and any ratification or implementation rules determine the actual local right.

Can annual leave replace maternity leave?

Annual leave can interact with maternity or parental leave, but it is not a universal replacement for those rights. Under the US FMLA, accrued paid vacation or sick leave may run concurrently with protected leave under the applicable rules. In Australia, paid annual leave may be taken at the same time as unpaid parental leave. Check the local interaction rule before substituting one leave balance for another.

Does maternity leave apply to contractors?

There is no universal maternity-leave entitlement for contractors. Eligibility can depend on the legal status of the relationship, contribution history and the relevant social-insurance system. In the UK, Maternity Allowance can be an alternative route for people who cannot receive Statutory Maternity Pay, including some self-employed claimants; that example does not create a rule for contractors everywhere.

Putting a country comparison to work

A country figure frames the case; the worker’s applicable rules determine the entitlement and employer cost. Check them in this order:

1. Define the comparison figure. Record whether it measures maternity protection, parental leave, paid weeks or full-rate-equivalent weeks. Note the reference date and whether the source covers national/federal rules only. A duration figure without those fields cannot answer what a worker will receive.
2. Identify the worker and governing system. Confirm employment status, work location and the applicable social-insurance system. Within the EU coordination area, start with where work is actually performed, then flag posting and multi-country work for a separate assessment.
3. Test leave and payment separately. Check the statutory leave test, then the benefit or statutory-pay test. Service history, earnings, contributions and evidence can matter to one route without changing the other. Where the standard payment does not apply, look for a verified alternative route before closing the case.
4. Build the operational handoff. Assign notice dates, proof, claim submission, employer responses, payment records, coverage and return-to-work steps to named owners. The UK example shows why a leave notice and an SMP claim need different deadlines and documents.
5. Add employer policy after the local check. Separate statutory benefits, reimbursements and any voluntary top-up. A global floor can be useful when its eligibility and relationship to higher local benefits are clear, but it should sit alongside the local process rather than replace it.

Sources

• Parental leave systems: OECD Family Database PF2.1 — OECD
• Maternity Protection Convention, 2000 (No. 183) — International Labour Organization
• Family and Medical Leave Act — U.S. Department of Labor
• Paid leave — U.S. Department of Labor Women’s Bureau
• Statutory Maternity Leave — GOV.UK
• Statutory Maternity Pay — GOV.UK
• Maternity protection before and after birth — Germany’s Familienportal
• Maternity benefits — Germany’s Familienportal
• Parental leave and related entitlements — Fair Work Ombudsman
• Payment during parental leave — Fair Work Ombudsman
• Maternity pay and leave eligibility — GOV.UK
• Maternity Allowance — GOV.UK
• Which rules apply to you? — European Commission
• Rates and thresholds for employers, 2026 to 2027 — GOV.UK
• How to claim maternity pay and leave — GOV.UK
• Maternity pay and leave: records for employers — GOV.UK
• Working paper W28672 on New York and Pennsylvania employers — National Bureau of Economic Research
• Enhancing paid leave benefits around the globe — Levi Strauss & Co.
• How Thomson Reuters developed its global standard for parental leave — HR Dive
• Family and Medical Leave Act FAQ — U.S. Department of Labor
• What is Elternzeit? — Germany’s Familienportal
• Back to work after maternity leave: Q&A with Catriona Spendlicek — Quensh