How U.S. Maternity Leave Policy Stacks Up to the U.K. and Germany

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Ten years ago, I moved to the U.S. from the U.K., where I was born and grew up. Although I already spoke the language, I noticed a few differences between the culture in the two countries.

One has to do with maternity leave. Here in the U.S. women are often unable to take any length of time off work following the birth of a child. In other countries mothers enjoy months of paid leave.

As a pregnant woman who is saving up to take maternity leave, I decided to dig a little deeper into the policies of three countries: the U.S., the U.K. and Germany.

U.S. policy

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The United States does not have a paid maternity leave policy. According to the Washington Post, this makes it the only developed country not to offer paid leave to new mothers. One in four new mothers returns to work just 10 days after her baby is born, according to USA Today.

If an American mother wants to take time off, she will likely have to dig into her sick and vacation leave, and potentially use unpaid time on top of that. With my first baby, who was born in Dayton, Ohio, I took 12 weeks off, five of which were paid. I had enough savings to cover that seven weeks (though I still had to cut back on expenses). Many women aren’t so fortunate.

Some women — me included — are entitled to 12 weeks’ unpaid leave from their jobs through the Family and Medical Leave Act, which President Clinton signed into law in 1993. Taking leave through this program protects your job until you return. But, according to the Institute for Women’s Policy Research, only around half of young mothers, age 18-34, are covered.

To qualify under the Family and Medical Leave Act, you must have worked for your employer for 12 months, and your company must employ at least 50 people within a 75-mile radius. That means many women who work for small businesses or for themselves are unable to take leave and must find an alternative solution to care for their newborns.

As someone who has experienced childbirth and the newborn phase once and will do so again in a few short months, I can tell you that even 12 weeks was not enough time to recover and bond with my daughter. I can’t imagine how difficult it is for women who are forced to return to work after a few weeks.

The National Conference of State Legislatures reports that, as of Jan. 1, four states offer some form of paid family leave: California, New Jersey, New York and Rhode Island. If you reside in one of the 46 other states — like Ohio, where I live — you’re out of luck.

Maternity Leave Policy in the U.K.

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New mothers in the U.K. have a very different experience than their American counterparts. According to Gov.UK, eligible employees can take up to 52 weeks of maternity leave. For those of you who aren’t great at math (like me), that’s an entire year.

U.K  leave is paid for the first 39 weeks. New mothers receive 90% of their average weekly earnings, before tax, for the first six weeks. The remainder of the time, they receive either £145.18 ($193.96 U.S. dollars or 90% of their average weekly earnings, whichever is lower.)

Mothers are able to start their leave up to 11 weeks before their estimated due date, and must take at least two weeks off after giving birth.

For a personal point of view, I spoke to Emily Wells, a medical photographer from the U.K. who is currently on maternity leave with her second child.

For both of her children, Wells was able to take 15 months’ leave.

She’s employed the U.K.’s National Health Service, and says the organization made the process of requesting maternity leave very easy. “They were very accommodating,” she said. “At around week 16 [of my pregnancy] they sat down with me and worked out my annual leave entitlements and the maximum maternity leave I could take.

“I had a great experience both times, and managed to get more than the maximum 52 weeks.”

Maternity Leave Policy in Germany

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In Germany, new mothers receive paid time off before and after the birth of a child, according to How To Germany. Pregnant women can start their maternity leave up to six weeks before their estimated due dates, though this is not mandatory.

“Having the six weeks off work before the birth was amazing,” said Mia (a pseudonym), who grew up in Belgium and now works in Germany as a controls analyst. “I was able to really focus on getting everything ready for the birth of my child.”

Mia is currently on maternity leave following the birth of her first child, and plans to take 12 months off altogether.

Following an uncomplicated birth, new mothers in Germany must, by law, take eight weeks off of work; that timeframe extends to 12 weeks if the baby was premature, the mother gave birth to multiples, or if she had a Cesarean birth.

Mothers are paid their full wage for the six weeks before and eight to 12 weeks after the birth.

In total, new parents in Germany are entitled to 14 months’ paid parental leave. After the mandatory eight to 12 weeks, they receive 65% of their net salary for the remainder.

“Two months on 65% of the net salary are reserved for the father, and the remaining 10 months can be taken by either parent, or together in tandem, also at 65%,” explained Mia. “We are also entitled to 36 months of unpaid parental leave with our jobs assured for us. So in our case I am taking the full 12 months of paid leave and my husband took two months of paid and seven months of unpaid leave.”

The main issues Mia encountered when arranging her maternity leave were due to language barriers. “HR wasn’t really helpful, but mostly because my German skills are dire,” she told me. “I had a conversation with my bosses and told them how many months I was planning to take off, and they signed off on the fact that we had discussed it. The difficulties I had were more language-related than anything else.”

Overall, Mia has been happy with the German policy. “I think the parental leave is fair,” she said “The fact that my husband is taking time off with me is amazing, and the knowledge that we are both able to go back to work without any fear of losing our jobs gives us great peace of mind. It’s just a little painful for our savings!”

Germany and the U.K. are just two examples of countries that provide paid leave to new mothers. Australian employers are required to provide 12 months of maternity leave, with the first 18 weeks paid. Estonia goes even further, providing 87 weeks of paid leave.

On the other side of the spectrum, four countries do not guarantee any paid time off for new mothers. Swaziland, Lesotho, Papa New Guinea. And the United States.

Catherine Hiles is a soon-to-be mother of two, and is saving like crazy to prepare for her second round of maternity leave. When she’s not pregnant and huge, she enjoys running, walking and chasing her 3-year-old daughter around.