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Mr. Gummer
The following table, drawn from the most recent information available, shows the provisions relating to maternity leave, including the right to return to work and maternity pay, in the European Community countries. Information on other European countries is not readily available.
It is however hazardous to make simple comparisons between levels of benefit in different countries because account must be taken of differences in wage levels, standards of living, taxation treatment and other social conditions, such as benefits available in the social security systems as a whole. The comparative table should therefore be treated with caution.
The rates of exchange used in the table are those reported in London in December 1981, when the most recent information available was gathered.
183W
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
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She must have been continuously employed by her employer for at least two years immediately before the beginning of the eleventh week before the expected week of confinement if she works 16 hours or more a week, or for at least five years if she works less than 16 hours a week but not less than eight hours. |
Maternity grant £25 |
Maternity grant Lump sum payment |
The employer may also request in writing, not less than 49 days after the notified expected week or notified expected week or notified date of confinement, confirmation that employee still intends to return. Employee must reply within 14 days, failure to do so within that time or as soon as reasonably practicalbe will lose her right to return. |
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At least 21 days before she stops work, she must tell her employer (in writing if requested) that she intends to stop work because of her condition. If it is not reasonably practicable to give three weeks' notice she may inform her employer of her intention less than three weeks before she stops work, or as soon as practicable after she stops work. |
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Women who are entitled to maternity allowance automatically qualify for maternity grant. |
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Maternity allowance |
Maternity allowance |
Maternity allowance |
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a. At least 26 paid contributions if insured before 6 April 1975 or |
£25.00 a week. Plus 1 Adult dependent — £15.45 a week. Each child—£0.30 a week. |
At least 18 weeks (from 11 weeks before expected week of confinement). |
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b. Contributions must have been paid or credited in the appropriate tax year, amounting to at least 50 times minimum weekly contribution for that year. |
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If the confinement is later than expected, the allowance may be paid for up to 6 weeks after the week of confinement. |
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A married woman residing with her husband cannot be paid any increase of maternity allowance, either for her husband or for a child, unless her husband is incapable of self-support. |
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Child benefit payable in addition. |
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Belgium |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
6 weeks |
8 weeks |
Maternity grant Insured with family allowance fund. |
Maternity grant 1st child-22,345 BFr (£307.25) |
Maternity grant Lump sum payment |
Woman must advise employer as soon as she is aware that she is pregnant, not necessarily in writing She must produce a medical certificate showing 'expected week of confinement'. For period of absence, contract suspended and absence treated as sickness. |
8 weeks after confinement. |
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2ndchild-15,412BFr (£211.92) |
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Each subsequent child 8,290 BFr (£113.99) |
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Maternity allowance |
Maternity allowance |
Maternity allowance |
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6 months' contributions. |
79.5% of earnings |
Manual worker— |
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1 week full pay from employer, then maternity allowance for 13 weeks. |
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Non-manual worker— |
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1 month full pay from employer, then maternity allowance for ten weeks. |
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Payable for up to 14 weeks (including 8 obligatory weeks after birth). |
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184W185W
Denmark |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
4 weeks |
14 weeks |
Maternity allowance All employed women. Yearly income which would have entitled claimant to at least 10% of daily allowance or earnings at this rate in 6 of the Last 12 months and in the last 4 weeks before absence. |
Maternity allowance 90% of average weekly earnings. |
Maternity allowance 4 weeks before confinement and 14 weeks after. |
Provided due notice of intention to return given, entitled to return to previous job. |
The period for which a woman's job may be considered to be protected after confinement remains to be tested in the courts. |
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Maximum benefit 1,850 KR (£130.23) a week. |
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Women who carry out domestic work in their own homes for at least one other person; insured for 10 months. |
According to rate of contribution. |
4 weeks after birth. |
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Maximum benefit 910 KR (£65.12) a week. |
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Federal Republic of Germany |
Antenatal leave |
Post-natal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
6 weeks |
8 weeks |
Maternity grant Insured women. Members of insured persons families, who earn less than 410 DM (£95.35) a month. |
Maternity grant 100 DM (£23–26) |
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4 weeks before the end of the maternity leave the mother is expected to inform the employer of her intentions to continue working. She may then give notice to the end of that period. For two months thereafter protection against dismissal is valid. If a woman wishes extension of maternity leave of up to six months after confinement, she must apply in writing giving two weeks notice. |
8 weeks after confinement or at the latest when child has become six months old. |
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12 weeks in the case of multiple and pre mature births. |
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Additional leave may be requested by mother up to the day when child is six months old. |
Maternity allowance 1. Employed women who were insured for 12 weeks between 10th and 4th month before confinement. |
Maternity allowance 1. 100% of average of last 3 months wages Maximum-25 DM (£5.81) a day Minimum-3.5 DM (£0.81) a day. If still employed, employer pays supplement equal to difference between benefit and net wages. |
Maternity allowance 6 weeks before expected date of confinement, then for the duration of maternity leave, i.e. up to the date on which the child is 6 months old. |
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2. Insured women who are not employed but who are entitled to sickness benefit. |
2. Maternity allowance payable equal to sickness benefit. |
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3. Insured women not entitled to sickness benefit. |
3. Lump-sum of 150 DM ££34.88) |
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4. Insured person's dependants who earn less than 410 DM (£95.35) a month. |
4. Lump-sum of between 35 DM (£8.14) and 150 DM (£34.88). |
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France |
Ante-natal leave |
Post-natal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
6 weeks |
10 weeks |
Pre-natal allowance ALL WOMEN |
Pre-natal allowance 3 instalments of 548.24 Fr (£50.41) 1,096.48 Fr (£100.83) and 822.36 Fr (£75.62) respectively, after each medical examination. |
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Employee must produce "Expected week of confinement" certificate and send it by registered post before commencing maternity leave. |
10 weeks after confinement |
If woman wishes to extend leave, she loses any right to reinstatement but retains a right to priority of re-engagement during year following end of maternity leave. |
May be extended to 8 weeks if there are pathological problems connected with pregnancy |
May be extended to 14 weeks if there are pathological problems connected with the pregnancy |
Pregnancy must be declared by end of the 15th week, and 3 medical examinations must be carried out (before the end of the 15th week of pregnancy, during the 6th month and the first pan of the 8th month). |
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No automatic right to old job. Replacement cannot be dismissed. Employee must advise employer by registered post, at least two weeks before intended return. Employer under obligation to offer first vacancy. |
If the child remains in hospital up to end of the sixth week following the birth, the woman may put back to the date of the end of hospitalisation the whole or part of the holiday to which she is already entitled. |
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May be extended by 2 weeks in the case of multiple births. |
Post-natal allowance ALL WOMEN 3 medical examinations of the child afterbirth. |
Post-natal allowance 2,292.64 Fr (£210.82) 473.48 Fr (£43.54) and473.48Fr(£43.54) respectively, after each medical examination plus in the case of multiple births, 2,467.08 Fr (£226.86) for the second infant and 5,694.22 Fr (£523.61) for the 3rd and any others. |
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186W187W
Ante-natal leave |
Post-natal leave |
Qualifying conditions for cash benefits |
Cask benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
In connection with the birth of a third child, women have a new right to 26 weeks' leave, eight of which are to be taken before the birth and the remainder afterwards. |
Maternity allowance INSURED WOMEN 200 hours of employment in the 3 months or the calendar quarter before the beginning of the 9th month preceding the expected date of confinement or the beginning of the maternity allowance period. 10 months of insurance or equivalent before the expected date of confinement. |
Maternity allowance 90% insurable earnings |
Maternity allowance 16 weeks including 10 weeks before confinement. (2 weeks more in cases of multiple births.) |
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Greece |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash |
Qualifying conditions for benefit reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
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Maternity grant All insured women; some urban self-employed women; dependants of insured persons. |
Maternity grant 18,750 Dr (£173.28). |
Maternity grant Lump sum benefit. |
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Special schemes for those employed in agriculture, the public service and parts of the private sector. |
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a. 50 days of contribution in last calendar year or in tbe 12 months before the last three months. |
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b. Payable also in cases of miscarriages or medically approved abortion after 6 months pregnancy. |
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Maternity allowance |
Maternity allowance |
Maternity allowance |
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All insured women; some urban self-employed women. |
50% of earnings according to wage class plus 10% of benefit for each dependant up to a maximum of 4. |
Up to 42 days before and 42 days after confinement. |
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Special schemes for those employed in agriculture, the public service and parts of the private sector. |
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200 days of contributions in last 2 years. |
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Minimum benefit 252 Dr (£2.33) a day. |
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Maximum benefit 1,260 Dr (£11.64) a day. |
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Maternity allowance supplement Insured women. |
Maternity allowance supplement |
Maternity allowance supplement |
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In receipt of maternity allowance and grant from IKA and under a contract of employment before the period of absence for pregnancy and confinement. |
The difference between maternity allowance and earnings. |
Up to 42 days before and 42 days after confinement. |
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Ireland |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
At least 4 weeks before expected week of confinement |
At least 4 weeks after expected week of confinement |
Maternity grant |
Maternity grant |
Maternity grant |
Employee must inform employer, in writing, not later than 4 weeks before the date on which she expects to return to work, of her intention to return to work and of the date on which she expects to return to work. |
At any time before the end of the 14 week maternity leave period provided that at least 4 weeks the expected week of confinement. |
Reinstatement period may be extended by a maximum period of 4 weeks by employee. |
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Insured women. |
IR £8.00 (£6.62) IR £300.00 (£248.24) for triplets and IR £400.00 (£333.99) for quadruplets; for which no insurance conditions are required. |
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Wives of insured persons. |
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The grant is paid on either the mother's own insurance, or ther husband's. If both are insured two grants may be payable. |
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Total maternity leave of 14 consecutive weeks—employee can choose how to apportion provided that the above minima are adhered to. |
Contributions paid in at least 26 weeks insurable employment before the date of confinement. |
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This notification must be confirmed in writing not earlier than 4 weeks and not later than 2 weeks before the date on which the employee expects to return to work. |
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188W189W
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
Employee may opt to take further leave of up to 4 more consecutive weeks running on from end of basic leave period. Notice must be given to employer at time of notification of basic leave or not later than 4 weeks before employee would be expected to return to work if additional leave were not taken. |
Contributions paid or credited in at least 26 weeks of the last complete contribution year before the beginning of the benefit year in which the confinement takes place or is any subsequent complete contribution year before the date of confinement. |
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Maternity allowance |
Maternity allowance |
Maternity allowance |
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Insured women. |
IR £23.30 (£20.94) a week. |
From 6 weeks before the expected date of confinement until 6 weeks after. May be extended if confinement occurs later than expected. |
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Contributions paid in at least 26 weeks of the last complete contribution year before the beginning of the benefit year in which the confinement takes place or in any subsequent complete contribution year before the date of confinement. |
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Pay-related supplement Insured women. |
Pay-related supplement |
Pay-related supplement |
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Claimant must have title to flat-rate maternity allowance and earnings of more than IR £20.000 (£16.55) a week. |
First 147 days—40% of insurable earnings between IR £20.00 (£16.55) and IR £170.00 (£140.67) a week. Next 78 days — 25% of above earnings. Final 78 days—20% of above earnings. |
Payable for 6 days a week for up to 381 days in a period of interruption of employment, starting from 13th day. For this purpose when spells of unemployment or incapacity for work or the maternity allowance period are separated by not more than 13 weeks they are linked together to form one period of interruption of employment. |
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Other medical benefits |
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All mothers with income under IR £8,500 (£7,033.51) in the tax year ended 5 April 1981 are entitled to general practitioner services during pregnancy and infant welfare services free of charge. |
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Maximum total benefit 100% of insurable earnings. |
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Maximum benefit total 100% of insurable earnings. |
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Maternity allowance scheme for women in employment |
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Insured women in employment are on maternity leave from work under the Maternity Protection of Employees Act, 1981 and entitled to resume work with the same employer at the end of the maternity leave period. |
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The claimant must satisfy the contribution conditions for the receipt of maternity allowance under the general scheme or the claimant must have contributions paid in at least 26 weeks of insurable employment in the 12 months immediately preceding the first day of a period of maternity leave. |
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80% of earnings in the relevant income tax year subject to a minimum payment of IR £45.75 (£37.86) a week. In 1982 the relevant income tax year is the 1980–81 year. |
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Payable for 14 weeks. The leave may commence as early as the 10th week but not later than the beginning of the 4th week before the expected confinement. |
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190W191W
Italy |
Ante-natal leave |
Post-natal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
2 calendar months. |
3 calendar months. |
Maternity allowance |
Maternity allowance |
5 months (2 months before and 3 months after the confinement). Optional absence for another 6 months until child is one year old. |
Entitled to returns to her old job. |
3 calendar months after confinement women may exercise option to take further leave for any six months period up to child's first birthday. |
If the woman exercises her option to take further leave (see previous column) employer must keep her job open for her. |
Maternity leave may start earlier than the eight week before confinement if the Labour Inspectorate considers continued working "too onerous" and "detrimental" to the woman concerned. |
Domestic workers must have at least 52 weekly insurance contributions in the 24 months, or 26 in the 12 months preceeding first day of leave. |
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Employee must have produced to employer a copy of certificate showing "Expected week of confinement" and must, within 15 days of confinement, produce a copy of the certificate of confinement. |
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Unemployed women if insured and employment ended not more than 60 days before the beginning of antenatal leave, or not more than 18 days before where they are in receipt of unemployment benefit or have paid at least 26 contributions in the past two years. |
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Netherlands |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period |
Alternative re-engagement conditions |
6 weeks |
6 weeks |
Maternity allowance |
Maternity allowance |
Maternity allowance |
Entitled to return to her old job. |
6 weeks after confinement. |
Leave following confinement may be extended if it is considered "medically necessary" |
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Insured women. |
100% of insurable earnings. |
12 weeks (6 weeks before and after confinement). |
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Maximum benefit |
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253.44 F1 (£53–64) a day, payable 5 days a week. |
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Luxembourg |
Antenatal leave |
Postnatal leave |
Qualifying conditions for cash benefits |
Cash benefits to employees |
Duration of cash benefit |
Qualifying conditions for reinstatement |
Reinstatement period reinstatement |
Alternative re-engagement conditions |
8 weeks |
8 weeks |
Maternity grant |
Maternity grant |
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After maternity leave a woman is entitled to return to "the same or an equivalent job". |
8 weeks after confinement. |
In the case of premature or multiple births or where the mother is breastfeeding the child leave following the confinement may be extended by 4 weeks. |
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All residents. |
36,399 LFr (£500.50) payable in 3 instalments of 12,133 LFr (£166.83) each. |
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1st instalment—paid when mother-to-be has had all the medical examinations required by law. |
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2nd instalment—paid after the birth of the child. If desired the first and second instalments may be paid together after the birth of the child. |
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3rd instalment—paid when the child has had the six medical examinations required by law. |
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Maternity allowance |
Maternity allowance |
Maternity allowance |
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Employed women. |
100% of earnings. |
Usually 16 weeks (8 weeks before and 8 weeks after confinement but can be extended to 20 weeks. |
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Insurance during 6 months in the year preceding confinement. |
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