Annual Leave Entitlement by Country: A Global Comparison (2026)

Annual leave entitlements vary enormously across the globe — from zero federal mandate in the United States to 30 days in France, Austria, and Denmark. Most developed nations guarantee at least 20 days of paid annual leave, but the minimums, accrual rules, carry-over provisions, and public holiday interactions differ country by country.

This article compares annual leave entitlements across 20 major economies, highlights the key differences, and explains what employers with international teams need to know.

Key Takeaways

• The EU Working Time Directive guarantees a minimum of 20 days across all member states, though most exceed it.
• France leads with 30 days (5 weeks), while the US has no federal minimum for paid annual leave.
• Public holidays add 8–15 days on top of annual leave in most countries, creating wide variation in total time off.
• Carry-over rules are the hidden differentiator — some countries allow unlimited carry-over, others use use-it-or-lose-it.

Global Comparison Table

Country	Paid annual leave (days)	Public holidays (approx.)	Total paid days off	Source
France	30	11	41	Code du travail
Austria	25	13	38	Arbeitszeitgesetz
Denmark	25	11	36	Ferieloven
Spain	22	14	36	Estatuto de los Trabajadores
Sweden	25	13	38	Semesterlagen
Norway	25	10	35	Ferieloven
Germany	20 (often 28–30)	9–13	29–43	BUrlG / collective agreements
Netherlands	20	8	28	Wet minimumvakantiedagen
Belgium	20	10	30	Wellbeing at Work Act
Italy	20	12	32	D.Lgs. 66/2003
Ireland	20	9	29	Organisation of Working Time Act
UK	28 (inclusive of 8 BH)	8 (included)	28	Working Time Regulations 1998
Australia	20	8	28	Fair Work Act 2009
New Zealand	20	11	31	Holidays Act 2003
Japan	10 (year 1) → 20 (year 6+)	16	26–36	Labour Standards Act
Singapore	7 (year 1) → 14 (year 5+)	11	18–25	Employment Act
Canada	10 (federal)	9–12	19–22	Canada Labour Code
India	15–30 (varies by state)	10–15	25–45	Shops & Establishments Acts
UAE	30	varies by emirate	30+	UAE Labour Law
United States	0 (federal)	11 (federal employees)	0–11+	No federal mandate

The Three Models

Most countries fall into one of three models for annual leave:

Model 1: Statutory Minimum Plus Public Holidays

The most common approach. The law sets a minimum number of annual leave days, and public holidays sit on top. France, Germany, and most of continental Europe follow this model. The total time off is the sum of both.

Model 2: Statutory Total Inclusive of Public Holidays

The UK is the clearest example. The statutory minimum is 28 days, and employers can include the 8 bank holidays within that total. The employee does not receive 28 days plus bank holidays — they receive 28 days total.

Model 3: No Federal Mandate

The US is the only OECD country with no federal requirement for paid annual leave. California, New York, and other states have introduced paid sick leave laws, but no state has mandated paid vacation. Annual leave in the US is entirely employer-driven.

Key Differences Beyond the Numbers

Accrual and Qualifying Periods

Some countries require a qualifying period before leave is available:

Country	Qualifying period	Notes
Japan	6 months	Leave may be granted after 6 months if 10+ days accrued
Singapore	None (from day 1)	But entitlement increases with service length
India	Varies by state	Some states require 12 months’ service
Most EU countries	None	Leave accrues from day one under EU law

Carry-Over Rules

This is where countries diverge most sharply:

• EU countries generally allow carry-over of at least 4 weeks, per the ECJ ruling in Schultz-Hoff (C-350/06). The remaining 1.6 weeks (in countries above 20 days) can be subject to use-it-or-lose-it rules.
• Australia allows annual leave to carry over indefinitely, but the employer can require it to be taken with reasonable notice.
• UK allows carry-over for the statutory 4 weeks if the employer prevented the employee from taking it, but the additional 1.6 weeks can be lost if the contract says so.
• Japan mandates carry-over of up to 20 days, but many employees do not take it — Japan had a national “Paid Leave Utilization Rate” of 62.9% in 2023.

Public Holiday Interaction

How public holidays interact with annual leave differs:

• UK: Bank holidays falling on weekends may or may not generate substitute days, depending on the contract.
• Australia: If a public holiday falls on a weekend and the employee would not otherwise work, they may be entitled to an additional day or a substitute day under some awards.
• Germany: If a public holiday falls on a Sunday, it is lost — there is no substitute.
• France: Public holidays on a Tuesday or Thursday often lead to “ponts” (bridges) — additional days off that are customary but not legally mandated.

What Employers With International Teams Need to Know

Multiple Leave Policies Are Inevitable

A single global leave policy that meets the minimum in every jurisdiction will be overly generous for some countries and non-compliant in others. The practical approach is:

1. Set a global minimum that meets the strictest jurisdiction you operate in.
2. Apply country-specific adjustments where local law requires more.
3. Track public holidays per country — they are not interchangeable.
4. Monitor carry-over rules per country, as they directly affect financial liability.

The Financial Impact of Carry-Over

In Australia, accrued annual leave appears as a liability on the balance sheet under AASB 101/IAS 19. For a 100-person Australian operation where each employee accrues 10 days per year and takes only 8, the accrued liability grows by approximately 200 days per year — a material figure in financial reporting.

In the UK, the same dynamic applies but is more constrained by carry-over limits. In Germany, the 20-day statutory minimum must be taken within the leave year or carried over to March 31 of the following year, after which it is lost (subject to illness or other protected reasons).

How Leave Balance Helps

Leave Balance manages annual leave entitlements across multiple countries in a single platform, applying the correct statutory minimum, public holiday calendar, carry-over rules, and accrual method per jurisdiction. For multinational employers, this means one system of record instead of spreadsheets per country.