The Right to Take a Vacation

Among wealthy countries, there are big differences with regard to paid time off from work. In most countries, vacation time is required by national law. We wonder: Which of these countries has the highest number of legally guaranteed vacation days?

A. United States
B. Germany
C. France
D. United Kingdom

A. United States is not correct.

The United States is the only country among the 34 member nations of the OECD, a grouping of advanced economies, where employers are not required to provide paid vacation time.

Moreover, according to the World Bank, aside from the United States, only six other countries worldwide do not require paid leave days for all workers. Apart from the African nation of Liberia, they are all Pacific island nations.

China mandates five days of paid leave for all workers. After the United States, it is the major economy with the fewest legally mandated vacation days in the world.

Because there is no U.S. mandate, almost one in four Americans (23%) has no paid vacation days (including holidays), according to an analysis by the Center for Economic and Policy Research.

The situation is even worse for lower-paid or part-time workers. For U.S. wage earners in the lowest 25%, only half received any paid vacation in 2012 — and those who did received just nine days. Only 35% of part-time workers receive any paid vacation days.

By comparison, 90% of all higher-wage workers (those in the top quarter) received paid vacation — an average of 16 vacation days in 2012. Differentiating the number of vacation days offered according to  income levels is illegal in the other OECD countries.

B. Germany is not correct.

In Germany, workers are guaranteed 24 paid leave days per year, according to the World Bank. This is generous compared with the United States, of course, but other countries offer still more. If public holidays are factored in, Germans receive a month of vacation and holiday time as a legal minimum annually.

In contrast to the situation in the United States, the European Union’s Working Time Directive, passed in 1993, requires a base level of 20 vacation days for workers in all EU member countries. Currently, 14 out of the 28 member states only offer that minimum.

Several European countries actually require employers to provide workers with extra pay for their vacation period. In Austria, for example, workers receive a “13th month” salary for that purpose, under the assumption that many fixed costs — such as rent and utility payments — still have to be made while people are on vacation.

C. France is correct.

Of the world’s 20 largest economies, France provides workers with the highest number of guaranteed paid leave days. Workers in France are guaranteed 30 paid days of leave each year.

The country is tied for the most generous in the world with a number of smaller economies, such as Djibouti and Togo, according to the World Bank.

Workers in Italy are guaranteed 26 days of paid leave. In Portugal and Spain, the number is slightly smaller, at 22. But while France has only one paid public holiday for workers beyond the paid leave days, Italy, Portugal and Spain have nearly two weeks’ worth of public holidays, according to an analysis by the Center for Economic and Policy Research.

Adding in these public holidays, workers in Italy, Portugal and Spain receive more paid time off than workers in France — making them among the most generous economies in the world by law.

That generosity of paid leave benefits for regular full-time employees in Southern European countries has given rise to so-called dual labor markets in these countries.

Because the national economy cannot afford such lavish benefits for all workers, others — mostly young, part-time workers — often work on short-duration contracts that provide fewer days of paid leave.

D. United Kingdom is not correct.

In the United Kingdom, employees receive a total of 28 days of paid annual leave. This includes the minimum 20 days mandated by the European Union, which workers can use any time, plus eight days to account for the country’s eight pre-existing legally defined “bank holidays.”

When the UK first adopted the EU mandatory minimum of 20 days, many employers interpreted the eight fixed holidays as being included in the 20 days, so that workers received just 12 days of flexible paid days off.

Trade unions lobbied for stricter compliance with the EU regulation, which is why the legal minimum is now 28 days, including bank holidays (if employers choose to close on those days).

Thus, while the UK and the United States have generally similar philosophies about how businesses and markets should be regulated, the similarity ends when it comes to paid leave for workers. U.S. workers receive far less vacation benefits than their British counterparts.

Japan and Canada — countries that are generally much more similar to the United States in terms of overall worker benefits than to continental Europe — range between the UK and U.S. vacation day totals. Japan and Canada mandate ten days of paid vacation for all workers.

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