No European harmony on holiday entitlement

Wide discrepancies continue across the EU in labour law and practices on paid holidays. Research by HR consultants William M. Mercer has shown that, when added together, annual leave and public holidays can range from 29 to 43 days depending on where you live.

The average leave and public holiday entitlements across all EU states is 36 days. Austria, Germany and Sweden provide the longest time off – 43, 42 and 41 days respectively. At the other extreme, Belgium and the UK provide only 31 days while Ireland gives just 29.

“Despite the moves to harmonise employment practices in Europe, we have still a long way to go in this area,” said Adelaide Barbier, research manager at William M. Mercer.

Mercer’s research was part of its global analysis of employment conditions and benefits in 55 countries worldwide. The findings are contained in its Worldwide Benefit and Employment Guidelines, 2000/2001.

Annual leave

The amount of leave granted is complicated by two factors: the minimum statutory requirement – which varies from 20 to 30 days – and actual industry practice.

Industry practice is to give between 23 and 25 days in most EU states. In Belgium and Italy, however, only 20 days are granted while the Germans and Austrians receive a full 30 days.

Public holidays

The diversity in public holiday entitlements is even stronger. Amongst EU member states, the average number of public holidays granted is 11. Workers are given the most time off in Portugal and Finland where there are 14 public holidays in the year. In the UK and Netherlands, however, there are just 8.

Across the EU, each year there are more than 50 different dates for national public holidays and many more including regional holidays. Yet 31 of these are observed by no more that one or two member states.

“Public holidays have their origin in history and local culture and it may be difficult to dismantle regional practices that are part of a long tradition. Nevertheless, as we become more of a pan-European community there could be increasing pressure to bring some degree of harmony here,” said Barbier.

Apart from the profusion of dates, there are also wide discrepancies in the implementation of employment practices governing public holidays. Most EU citizens have a statutory right to public holidays with the exception of those working in France, Sweden and the UK. While it is normal practice to grant public holidays in these countries, employers are within their rights to require employees to work on these days, or include public holidays as part of annual leave entitlement. In Ireland, employers are not obliged to grant actual public holidays as time off – they may be given extra pay or days off in lieu. In Portugal, employees are not entitled to additional days off when public holidays fall on days not normally worked.

Working hours

The EU Working Time Directive introduced a maximum 48-hour working week across Europe, yet its impact has been minimal on the plethora of different local conditions in member states.

“Local requirements for working hours are something of a minefield for multinational employers. Although the EU Directive has helped, local variations abound, complicated by the discrepancies in statutory requirements and actual practice through collective agreements,” said Barbier.

Nine of the EU states have legislated for a maximum of 40 hours a week. In contrast, France has introduced a statutory maximum of just 35 hours while Denmark, Ireland and the UK retain a statutory 48 -hour week. In practice, the number of hours worked across the EU ranges between 37 and 40 hours due to industry practice through collective agreements.

“We are watching with interest the impact in Europe of France’s new 35-hour limit. Already, Greece and Spain are considering similar policies as a means of generating employment,” Barbier. “Such a move presents real complications for management. In many cases it is not possible to reduce working hours at a stroke and many French employees are accumulating weeks of extra vacation or early retirement years in lieu. The question is whether, in the long term, multinational companies might view other countries as more flexible and attractive in the global labour market.”

International comparisons

Around the globe, legislation for maximum working hours of 40 to 48 hours has been passed in most of the 55 countries studied. Countries such as India, Thailand and Vietnam tend towards the 48-hour maximum both in legislation and practice.

The research noted that east Europeans tend to work up to four hours longer each week than citizens of the European Union.

In the US and Canada, 40 hours is the norm though, interestingly, the US is one of very few nations globally that has not established maximum hours or annual leave entitlements through formal legislation. Normal leave entitlement in the US and Canada is amongst the lowest in the world.

Statutory annual leave varies from just 11 days in Singapore to 30 in Brazil, with actual leave practices averaging at around 18 to 20 days. In Brazil, the number of days’ leave is reduced for employees with high sickness absence rates. Japan is the only westernised country where normal leave practice is below the statutory level. “Japanese employees are often reluctant to take their full entitlement as this may not be viewed positively by their employers,” said Barbier.

Outside Europe there is a wide range of different public holidays granted, the majority marking traditional religious festivals. New Year’s Day and Christmas Day are almost universally celebrated throughout the world, irrespective of local religions and cultures.

Copies of the Worldwide Benefit and Employment Guidelines are available from Olivier Meier.

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