Leave Policy Cheat Sheet: Statutory Minimums for 20 Countries
Your Leave Entitlement Depends on Where You Work
If you work in France, the law guarantees you 25 days of paid annual leave before a single public holiday is counted. If you work in the United States, the federal government guarantees you exactly zero.
That gap is one of the widest in the developed world, but it is far from the only surprise. Statutory minimums vary dramatically across regions, and even neighboring countries can differ by a week or more. Japan mandates only 10 leave days for new employees but stacks 16 public holidays on top, while the Netherlands offers 20 leave days but only 8 public holidays.
This guide is a quick-reference for workers, remote teams, and HR professionals who need to compare entitlements across borders. Bookmark it and use it the next time someone asks "how much time off do I actually get?"
The 20-Country Reference Table
The figures below reflect statutory minimums for full-time employees. Many employers offer more than the legal floor. "Carry-over" describes whether unused days can roll into the following year under standard conditions.
| Country | Statutory Min Days | Public Holidays | Total Guaranteed | Carry-Over | Notes |
|---|---|---|---|---|---|
| United Kingdom | 28 (incl. public holidays) | 8 | 20 + 8 | Employer discretion | 28-day entitlement includes bank holidays by default; contract may separate them |
| United States | 0 | 0 federal mandate | 0 | N/A | No federal law requires paid leave or paid holidays; averages ~10-15 days by employer policy |
| Australia | 20 | 8 | 28 | Yes -- accumulates indefinitely | Leave loads at 17.5% extra pay in many awards |
| Canada | 10 (federal) | 6 federal | 16 | Varies by province | Provincial laws range from 10 to 15 days; some provinces add holidays |
| Germany | 20 | 9-13 (varies by state) | 29-33 | Must be used by Mar 31 next year | Many employers offer 25-30 days; Bavarian workers get the most public holidays |
| France | 25 | 11 | 36 | Limited -- generally must use within period | RTT (reduction of working time) days can add 10+ extra days in some contracts |
| Netherlands | 20 | 8 | 28 | Statutory days expire after 6 months into next year | Employers often offer 25+ days; extra-statutory days may have longer carry-over |
| Sweden | 25 | 13 | 38 | Yes -- can save up to 5 days/year for up to 5 years | One of the highest combined totals in the world |
| Norway | 25 | 10 | 35 | Yes -- mandatory carry-over of unused days | Workers over 60 get an additional week |
| Denmark | 25 | 11 | 36 | Can carry over up to 5 days by agreement | Leave year runs Sep 1 to Aug 31 |
| Poland | 20 or 26 | 13 | 33-39 | Must be used by Sep 30 next year | 26 days after 10 years of employment (education counts toward tenure) |
| Spain | 22 | 14 | 36 | Generally no -- must use within calendar year | 14 public holidays is among the highest in Europe |
| Italy | 20 | 12 | 32 | Must use at least 2 weeks within the year; remainder within 18 months | National contracts (CCNL) often raise the minimum substantially |
| Portugal | 22 | 13 | 35 | Can carry over with employer agreement | Workers gain additional days with seniority under some contracts |
| Japan | 10 (year 1) up to 20 | 16 | 26-36 | Yes -- up to 2 years | Employers must ensure workers take at least 5 days; actual usage averages ~50% |
| South Korea | 15 (year 1) up to 25 | 15 | 30-40 | Employer may buy out unused days | Unused leave compensation is common; culture is shifting toward actual use |
| India | 15 (Shops & Establishments Acts vary) | 10-15 (varies by state) | 25-30 | Yes -- typically up to 30-45 days accumulated | Entitlements differ significantly by state legislation and sector |
| Singapore | 7 (year 1) up to 14 | 11 | 18-25 | Employer discretion | Annual leave increases with tenure; 14 days reached after 8 years |
| Brazil | 30 | 12 | 42 | Must use within 12 months of accrual | Workers can sell back up to 1/3 of leave days for pay |
| South Africa | 21 consecutive days (15 working days) | 12 | 27 | Must use within 6 months of end of leave cycle | "21 consecutive days" is the statutory language; equates to 15 business days |
Regional Patterns
Europe: The Gold Standard
The EU Working Time Directive sets a floor of 4 weeks (20 days) for all member states, but most countries exceed it. When public holidays are added, total guaranteed time off typically lands between 28 and 39 days.
- Sweden and Norway combine 25 statutory days with double-digit public holidays, producing totals above 35.
- Spain has 14 public holidays -- more than almost any country on this list -- pushing its total to 36 even with a modest 22-day statutory base.
- France layers RTT days on top of a 25-day minimum, meaning some workers effectively receive 35+ leave days before counting public holidays.
Asia-Pacific: A Wide Spectrum
Asia-Pacific has the widest variation. Japan and South Korea have reasonable statutory floors (10-15 days in year one, scaling upward), but cultural pressure to avoid taking leave means actual usage can lag far behind entitlement. Japan's government has actively campaigned to raise its notoriously low leave-utilization rate.
Singapore starts low at 7 days for first-year employees, scaling to 14 over eight years. India's entitlements are fragmented across state-level legislation, making generalizations difficult -- always check your specific state's Shops and Establishments Act.
Australia is the exception in the region: 20 statutory days, indefinite carry-over, and a cultural norm of actually using them.
Americas: The US Is the Outlier
Brazil mandates 30 days of annual leave -- one of the highest figures globally. Canada requires 10 days at the federal level, with provinces layering additional entitlements.
Then there is the United States -- the only advanced economy with no federal mandate for paid annual leave or paid public holidays. The average US worker receives about 11 days of PTO, but this is entirely at the employer's discretion. Workers in lower-wage or part-time roles frequently receive nothing.
Common Misconceptions
"Public holidays count toward my annual leave"
In some countries, yes. The UK's 28-day statutory entitlement includes bank holidays by default -- your employer can count those 8 days against your 28, leaving you with just 20 discretionary days. In most of Europe, however, public holidays are separate from annual leave. Always read the fine print in your contract.
"I lose unused days at year-end"
This varies enormously. Australia lets leave accumulate indefinitely. Germany requires you to use statutory leave by March 31 of the following year. The Netherlands splits the difference: statutory days expire 6 months into the next year, but extra-statutory days may carry over longer. Brazil requires leave to be used within 12 months of accrual, or the employer must pay double.
Check your country's rules and your employer's policy separately -- they are often different.
"Part-time workers get fewer holidays"
In most developed countries, part-time workers are entitled to annual leave on a pro-rata basis. A worker on a 3-day week in the UK still gets 28 x 3/5 = 16.8 days. The proportion does not shrink just because you work fewer days.
If you work part-time and suspect your leave is being calculated incorrectly, compare your entitlement to the full-time statutory minimum using a pro-rata formula.
How to Check Your Actual Entitlement
Statutory minimums are the floor, not the ceiling. Here is how to determine what you are actually entitled to:
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Start with the law. Identify your country's (and state's or province's) statutory minimum. The table above is a starting point, but verify against current legislation -- governments update these periodically.
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Read your employment contract. Many employers exceed the statutory minimum. Your contract will specify your actual entitlement, carry-over rules, and restrictions on when leave can be taken.
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Check for collective agreements. In countries like France, Italy, and Germany, sector-level collective bargaining agreements often set higher entitlements than the statutory baseline.
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Account for tenure. Several countries (Japan, South Korea, Singapore, Poland) increase entitlement based on years of service. Make sure you are claiming the correct tier.
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Separate public holidays from annual leave. Confirm whether your employer treats public holidays as part of your leave entitlement (as in the UK default) or in addition to it. This distinction alone can represent 8-16 days per year.
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Ask HR directly. If anything is unclear, put the question in writing. A simple email creates a record and usually gets a precise answer.
Make Every Day Count
Knowing your entitlement is step one. Step two is using those days strategically. A single PTO day placed between a public holiday and a weekend can turn into four or five consecutive days off. Multiply that across the year and you can turn 20 leave days into 45+ days away from work.
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