Sick Leave Across Europe: How Every Major Country Handles It

If your organisation employs people across Europe, sick leave is one of the most complex areas to get right. Every country has its own rules on who pays, how much, for how long, and what documentation is required. The differences are not minor — they range from the Netherlands requiring employers to pay 70% of salary for up to two years, to the UK’s relatively modest Statutory Sick Pay of £116.75 per week.

This guide breaks down the sick leave rules in 12 major European countries, with a comparison table so you can see the differences at a glance. Whether you are expanding into new markets or managing an existing multi-country workforce, this is the reference you need.

Quick Comparison Table

Country	Who pays first?	Employer payment period	State/insurance payment period	Waiting period	Pay rate	Medical certificate required
UK	Employer (SSP)	Up to 28 weeks	ESA after SSP ends	3 waiting days	£116.75/week flat rate	After 7 days (fit note)
Germany	Employer	6 weeks at 100%	Up to 78 weeks at ~70%	None	100% then ~70%	From day 1 (or day 4 by agreement)
France	Social security	Employer top-up varies	Up to 3 years	3 days	50% from social security + employer top-up	Within 48 hours
Netherlands	Employer	Up to 104 weeks (2 years)	WIA after 2 years	None	70% minimum (often 100% year 1)	Company doctor assessment
Sweden	Employer days 2–14	13 days	Up to 364 days (then extended)	1 qualifying day	80% from Försäkringskassan	After 7 days
Spain	Employer days 1–15	15 days	Up to 12 months (+6 extension)	None for work injury; 3 days for common illness	60–75%	From day 1 in practice
Italy	Employer (INPS reimburses)	First 3 days (carenza)	Up to 180 days/year	3 days at reduced/no pay	50–66.67% from INPS	From day 1
Ireland	Employer	Up to 5 days (2026)	Illness Benefit up to 2 years	3 waiting days for state benefit	70% of gross (capped at €110/day)	After 3 days
Poland	Employer	First 33 days (14 if over 50)	Up to 182 days	None	80% (100% for pregnancy/accidents)	From day 1 (e-ZLA)
Belgium	Employer	30 days at 100%	Up to 1 year (then invalidity)	1 day (abolished for some)	60% from mutual insurance	From day 1 (or day 2 for some)
Portugal	Social security	None (state pays from day 4)	Up to 1,095 days	3 days	55–75% depending on duration	From day 1
Denmark	Employer	First 30 days	Up to 22 weeks	None	Full pay (capped) from employer, then municipality	From employer’s request

United Kingdom: Statutory Sick Pay (SSP)

The UK’s sick pay system is one of the least generous in Europe, relying on a flat-rate payment rather than a percentage of salary.

How It Works

• Statutory Sick Pay (SSP) is £116.75 per week (2025/26 rate)
• Paid by the employer for up to 28 weeks
• The employee must earn at least £123 per week (the Lower Earnings Limit) to qualify
• There are 3 waiting days before SSP kicks in — the employee receives nothing for the first three qualifying days of sickness

Medical Certification

• For the first 7 days, employees can self-certify
• From day 8 onwards, a fit note (previously called a sick note) from a GP or other authorised healthcare professional is required
• Fit notes can state the employee is either “not fit for work” or “may be fit for work” with adjustments

After SSP Ends

If the employee is still unwell after 28 weeks, they may be eligible for Employment and Support Allowance (ESA) or Universal Credit from the state. The employer’s obligation to pay ends.

Employer Top-Up

Many UK employers — particularly larger organisations — offer occupational sick pay schemes that go beyond SSP, often providing full pay for a set number of weeks followed by half pay. These are contractual and vary widely.

Germany: The Gold Standard for Employer-Funded Sick Pay

Germany has one of the strongest sick pay protections in Europe, with employers bearing the full cost for the first six weeks.

How It Works

• The employer pays 100% of the employee’s salary for the first 6 weeks of each illness (Entgeltfortzahlung)
• After 6 weeks, the statutory health insurance fund pays Krankengeld (sickness benefit) at approximately 70% of gross salary (capped at 90% of net salary) for up to 78 weeks within a three-year period for the same illness
• If an employee recovers and then falls ill with a different condition, the 6-week employer obligation resets

Medical Certification

• Traditionally required from day 1 (the Arbeitsunfähigkeitsbescheinigung or AU)
• Since 2023, the process is digital — doctors submit the certificate electronically to the health insurance fund, and employers retrieve it (the eAU system)
• Some employers allow self-certification for the first 3 days, but the legal default is day 1

The Six-Week Reset Rule

This is crucial for employers to understand. The 6-week employer payment period restarts for each new, unrelated illness. However, if an employee has the same illness recur, the employer only has to pay again if:

• The employee was fit for at least 6 months between episodes, or
• 12 months have passed since the start of the first absence

Return to Work

Germany has a structured Betriebliches Eingliederungsmanagement (BEM) process — an occupational reintegration management programme. Employers must offer BEM to any employee who is absent for more than 6 weeks (cumulative) within a 12-month period. It is not mandatory for the employee to participate, but the employer must offer it.

France: Social Security Leads, Employers Top Up

France operates a dual system where social security provides a baseline and employers supplement it, with specifics often determined by collective agreements.

How It Works

• There is a 3-day waiting period (carence) during which the employee receives no statutory sick pay (though many collective agreements eliminate this)
• From day 4, the Caisse Primaire d’Assurance Maladie (CPAM) pays 50% of the daily base salary (capped at approximately €53/day in 2025)
• Employers are required to top up the social security payment under the loi de mensualisation — typically to 90% of gross salary for the first 30 days, then 66.67% for the next 30 days, with the exact duration depending on length of service
• Social security payments can continue for up to 3 years for the same condition (with reviews)

Medical Certification

• A medical certificate (arrêt de travail) must be sent to the CPAM within 48 hours
• The employer receives a copy (the volet employeur)
• The CPAM can and does carry out checks, including home visits, to verify the employee is genuinely unwell

Key Detail: The Carence and Collective Agreements

Many collective bargaining agreements (conventions collectives) in France eliminate the 3-day waiting period entirely or reduce it. Some also provide 100% salary maintenance from day 1. Always check the applicable convention collective for your industry.

Netherlands: The Most Generous — and Most Expensive for Employers

The Netherlands has the longest employer-funded sick pay obligation in Europe, and it is not even close.

How It Works

• Employers must pay at least 70% of salary during the first year of illness and at least 70% during the second year — for a total of up to 104 weeks (2 years)
• In practice, most collective labour agreements (CAOs) require 100% in year 1 and 70% in year 2
• There is no waiting period
• After 2 years, the employee may qualify for WIA (Work and Income according to Labour Capacity Act) benefits from the state

The Employer’s Obligations Beyond Pay

Dutch employers have extensive obligations during the 2-year period:

1. Engage a company doctor (bedrijfsarts) who must assess the employee within 6 weeks
2. Create a Plan of Action (Plan van Aanpak) within 8 weeks, outlining steps for return to work
3. Offer modified or alternative work if the employee can do some form of work
4. Report to UWV (the Employee Insurance Agency) at week 42
5. Apply for WIA assessment at 88 weeks if the employee has not recovered

If the employer fails to meet these obligations, UWV can impose a wage sanction — requiring the employer to continue paying for a third year.

Why This Matters for International Employers

The Dutch sick pay system is the single most expensive employer obligation in Europe. Many companies hiring their first Dutch employees are stunned by the cost and administrative burden. Budget for it and ensure your contracts and insurance arrangements account for it.

Sweden: Structured State Support After Two Weeks

Sweden balances employer and state responsibility with a clear handover point.

How It Works

• Day 1 is a “qualifying day” (karensdag) — the employee receives no pay
• Days 2–14: The employer pays 80% of salary (sjuklön)
• From day 15: The Försäkringskassan (Swedish Social Insurance Agency) pays approximately 80% of salary up to a ceiling (SGI cap of approximately SEK 43,000/month in 2025)
• Benefits from Försäkringskassan can continue for up to 364 days, with the possibility of extension in exceptional cases at a reduced rate (75%)

Medical Certification

• Self-certification is accepted for days 1–7
• A medical certificate (läkarintyg) is required from day 8
• The certificate must specify the diagnosis and expected duration

Rehabilitation Responsibility

Swedish employers have a duty to investigate what adjustments can be made to enable the employee to return to work. The Försäkringskassan actively coordinates rehabilitation plans and can require the employee to participate.

Spain: Social Security Takes Over After Two Weeks

How It Works

• For common illness (contingencias comunes): the first 3 days are unpaid (unless the collective agreement says otherwise), days 4–15 are paid by the employer at 60% of the regulatory base, and from day 16 the social security system (INSS) pays at 60% (days 4–20) then 75% (from day 21)
• For work-related illness or accident (contingencias profesionales): 75% from day 1, paid by the employer but reimbursed by the social security mutual (Mutua)
• Maximum duration: 12 months, extendable by 6 months if recovery is expected

Medical Certification

• A medical report (parte de baja) is required from day 1
• Follow-up reports (partes de confirmación) are required at regular intervals depending on expected duration
• A discharge report (parte de alta) is needed to return to work

The IT (Incapacidad Temporal) System

Spain’s temporary incapacity (IT) system is tightly regulated. The Mutua or INSS can call the employee for medical assessments and can discharge them if they are deemed fit to return.

Italy: INPS-Funded with Employer Obligations

How It Works

• The first 3 days (periodo di carenza) are paid by the employer, typically at a reduced rate (often 100% under many collective agreements)
• From day 4, INPS (the national social insurance body) pays:
  • 50% of average daily pay for days 4–20
  • 66.67% for days 21–180
• Most collective agreements (CCNL) require employers to top up to 100% for a specified period
• Maximum duration: 180 days per year (calendar year)

Medical Certification

• The employee must notify the employer and obtain a medical certificate from day 1
• Since 2010, certificates are sent electronically by the doctor to INPS, who share them with the employer
• INPS can carry out home visits to check on the employee during specified reperibilità hours (typically 10:00–12:00 and 17:00–19:00)

Ireland: The New Statutory Framework

Ireland introduced statutory sick pay for the first time with the Sick Leave Act 2022, with a phased implementation.

How It Works (2026 Onwards)

• Employers must provide 5 days of paid sick leave per year (increased from 3 days in 2024 and 5 days from 2025, with 7 days expected from 2026 — subject to statutory instrument confirmation)
• Pay rate: 70% of gross salary, capped at €110 per day
• The employee must have 13 weeks of continuous service to qualify
• After statutory sick pay is exhausted, employees may claim Illness Benefit from the Department of Social Protection for up to 2 years (with a 3-day waiting period for the state benefit)

Medical Certification

• A medical certificate is required from day 1 for statutory sick pay claims
• Illness Benefit claims require ongoing certification

The Transition Period

Ireland’s system is still maturing. Many employers already offered contractual sick pay before the 2022 Act. The statutory entitlement is a floor, not a ceiling — employers can and do offer more generous schemes.

Poland: Electronic Certificates and High Coverage

How It Works

• The employer pays for the first 33 days of sickness per calendar year (14 days for employees over 50)
• After that, ZUS (Social Insurance Institution) pays sickness benefit (zasiłek chorobowy) for up to 182 days (270 days for tuberculosis or pregnancy-related illness)
• Pay rate: 80% of the assessment base (100% for workplace accidents, pregnancy, or illness during pregnancy)

Medical Certification

• Poland uses an electronic system called e-ZLA — doctors issue certificates digitally to ZUS, who notify the employer
• Certificates are required from day 1
• ZUS actively monitors and can check on employees

Belgium: Guaranteed Pay Then Mutual Insurance

How It Works

• Employers pay 100% of salary for the first 30 calendar days (the guaranteed wage period — gewaarborgd loon)
• After 30 days, the employee receives benefits from their mutual insurance fund (mutualiteit/mutualité) at approximately 60% of salary (capped) for up to 1 year
• After 1 year, the employee moves to invalidity status with continued benefits at a reduced rate

Medical Certification

• A medical certificate is technically required from day 1
• Belgium previously abolished the requirement for certificates for single-day absences for companies with 50+ employees (from November 2022), but employers can still require them for the first three single-day absences per year
• The mutual insurance fund’s advisory doctor (médecin-conseil) actively manages longer absences

Key Patterns Across Europe

After examining all these systems, several patterns emerge that international employers should understand.

Who Pays: Employer vs State

The spectrum runs from the Netherlands (employer pays for 2 years) to Portugal (state pays from day 4 with no employer obligation). Most countries use a hybrid model where the employer covers an initial period and the state or social insurance takes over.

Generosity

The Netherlands, Germany, and the Scandinavian countries offer the most generous protection. The UK’s SSP flat rate is widely regarded as the least generous system in Western Europe — a point that often surprises UK employers expanding into the EU.

Documentation Trends

Most European countries are moving towards electronic medical certification systems. Germany’s eAU, Poland’s e-ZLA, and Italy’s electronic INPS certificates are examples of this trend. The days of paper sick notes are numbered.

Employer Obligations Beyond Pay

The Netherlands, Germany, and Sweden all impose significant return-to-work and rehabilitation obligations on employers. This goes beyond just paying sick leave — employers must actively work to reintegrate the employee.

Practical Tips for Multi-Country Employers

1. Budget differently for each country. The cost of sick leave varies enormously. Dutch operations need significantly higher contingency budgets than UK ones.
2. Check collective agreements. In France, Germany, Italy, and Spain, the collective bargaining agreement for your industry often significantly enhances the statutory minimum.
3. Set up proper tracking by country. You need to know which rules apply to which employees and track waiting periods, payment switches between employer and state, and certificate deadlines.
4. Consider insurance. In the Netherlands especially, sick leave insurance (verzuimverzekering) is common and strongly recommended for smaller employers.
5. Communicate clearly with employees. Employees relocating between countries need to understand that their sick leave entitlements change.

How Leave Balance Helps You Manage Sick Leave Across Europe

Managing sick leave across multiple European countries in a single spreadsheet is a recipe for compliance failures. Each country has different rules, different payment periods, different documentation requirements, and different thresholds.

Leave Balance’s multi-country support lets you configure sick leave policies per country, with the correct entitlements, waiting periods, and tracking rules built in. When an employee in the Netherlands enters their fourth week of illness, the system knows the rules are different from those that apply to your UK team.

Your managers see a unified dashboard across all countries, while the underlying policies respect local regulations. Employees can log sick leave through Slack or Teams, and the system handles the tracking and calculations.

At $10/month flat rate for unlimited employees across unlimited countries, you are not paying extra for each new market you expand into. Start a 14-day free trial — no credit card required — and see how Leave Balance simplifies multi-country leave management.