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PTO policies around the world: A 2026 guide

James Kelly

Author

James Kelly

Last Updated

14 August 2026

Read Time

8 min

Paid time off is one of the areas where employment rules differ most from country to country. A policy that is generous in one market can be below the legal minimum in another, and an employer hiring across borders cannot simply apply a single global template. Statutory minimums, sick leave rules and public holidays all vary, and all of them are mandatory where they apply.

This guide explains the three components of paid time off, how statutory minimums differ around the world and what employers hiring internationally need to keep in mind.

Paid time off is not one entitlement but several, and the terminology varies by region. In broad terms there are three components.

The first is annual leave, sometimes called vacation, which is paid time away from work for rest. The second is sick leave, paid time off when an employee is unwell, which often has its own rules and its own funding mechanism. The third is public holidays, the nationally or regionally recognised days on which work typically pauses. Some countries roll these together loosely under PTO, but legally they are usually distinct, with separate rules for each.

PTO terminology can vary by country. In the US, PTO often means one combined pool of paid leave that employees can use for vacation, illness or personal reasons. In many European countries, annual leave and sick leave are separate legal entitlements, each with its own rules. A company cannot simply combine them unless the policy still meets all local requirements.

This matters when applying a US-style PTO policy internationally. Deducting sick days from an employee’s vacation allowance may not meet statutory sick leave requirements. Public holidays may also need to sit outside annual leave, depending on the country. In the UK, for example, bank and public holidays can be included within the statutory annual leave entitlement.

Terminology can also cause confusion. In the UK, “holiday” usually means annual leave, while in the US it often refers to a public holiday. Global policies should therefore use clear terms such as **annual leave, sick leave and public holidays** rather than relying on “PTO” or “holiday” alone.

Statutory annual leave varies widely. The European Union sets a floor through the Working Time Directive, requiring at least four weeks of paid annual leave, and many member states go well beyond it. France, for example, provides a high statutory entitlement, and several countries add further days based on age or service.

The contrast with the United States is stark. There is no federal statutory minimum for paid vacation in the US, so entitlement is a matter of employer policy rather than law. Other markets sit in between, and some, such as those in parts of Asia and Latin America, tie entitlement to length of service so it rises over time.

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    Sick leave is just as varied, and the key differences are duration, pay level and who funds it. In some countries the employer pays sick leave directly for an initial period, after which a state or social security scheme takes over. In others the social security system carries most of the cost from early on.

    The pay level also differs. Some systems require full pay during sickness, others a defined percentage, and the entitlement can depend on length of service or the nature of the illness. Treating sick leave as a single global concept is a common mistake, because the funding and the rules behind it change market by market.

    Public holidays range from a handful to well over a dozen days a year depending on the country, and in some cases the region within it. They are typically paid, and where an employee is required to work a public holiday, many countries mandate premium pay or a compensating day off.

    Because public holidays are set nationally or regionally and change from year to year, they have to be tracked per market. An employer with people in several countries is effectively managing several different holiday calendars at once.

    Country

    Public holidays a year

    Substitute day if it falls at a weekend

    How working the day is paid

    United Kingdom

    8 in England and Wales, 9 in Scotland, 10 in Northern Ireland

    Yes, normally the following Monday

    No statutory premium. Contract or policy decides

    Ireland

    10, after St Brigid's Day was added in 2023

    Handled through the entitlement rather than a substitute date

    Statutory: a paid day off, an extra day's pay, or a day off within a month

    France

    11 nationwide, with extra days in Alsace-Moselle

    No

    Only 1 May carries a statutory right to double pay. Other days depend on the collective agreement

    Germany

    9 nationwide, rising to between 9 and 13 depending on the Bundesland

    No

    No single statutory premium. Collective agreements commonly set one

    Spain

    14 in total, made up of national, regional and local days

    National days falling on a Sunday move to the Monday

    Compensatory time off or a premium, set by the collective agreement

    Netherlands

    11

    No

    No statutory right to the day off or to a premium. The CAO decides

    Poland

    14, after Christmas Eve was added from 2025

    A holiday falling on a Saturday gives an extra day off in the same settlement period

    Premium pay or a substitute day off

    United States

    11 federal holidays

    Not applicable to private employers

    No federal requirement to give the day off or to pay a premium

    India

    3 national holidays, with the rest set at state level

    Set at state level

    Set at state level

    Annual leave entitlement is only the starting point. How leave accrues, when it expires, whether it carries over and how unused leave is paid out all depend on local rules. 

    • Leave often builds up over time: In many countries, employees accrue leave monthly or based on hours worked. Entitlement is usually pro-rated for part-time employees and people who join or leave during the year. This means a new hire may not have access to their full annual allowance from day one.
    • The leave year may not follow the calendar year: In Denmark, for example, the holiday year runs from 1 September to 31 August. Employees accrue 2.08 days of leave per month and can use leave as they earn it. Our guide to the Danish Holiday Act explains the rules in more detail.
    • Carry-over rules vary by country: In many EU countries, employees are expected to use at least four weeks of annual leave during the relevant period. However, unused leave cannot always expire automatically. Following the Max-Planck-Gesellschaft v Shimizu ruling, employers may need to show that employees were given a genuine opportunity and clear notice to take their leave before it expired.
    • Unused statutory leave usually cannot be exchanged for cash during employment: Statutory leave is intended to provide time away from work. However, when employment ends, unused statutory leave generally has to be paid out. The calculation may include regular overtime, commission or allowances in some countries, rather than base salary alone.

    The practical takeaway is that paid time off cannot be standardised across a global team without checking each market’s floor. A company can offer a single generous policy, but it must still meet or exceed the statutory minimum for vacation, sick leave and public holidays in every country where it employs people. Falling below the local minimum is non-compliant regardless of how generous the overall policy looks.

    This is where an Employer of Record removes the burden. As the legal employer in each country, Boundless applies the correct statutory entitlements for annual leave, sick leave and public holidays automatically, so every team member receives at least what local law requires. Pricing starts from €175 per month with transparent costs, and coverage spans 110+ countries backed by Payoneer, a public company listed on the NASDAQ.

    Next 15 used Boundless to employ people across multiple markets without having to learn each country’s leave rules, keeping every hire compliant while their teams focused on the work.

    Unlimited PTO removes the ceiling on leave, but it does not remove local minimum requirements. In countries with statutory leave entitlements, employers still need to make sure employees receive at least the legal minimum.

    • Statutory minimums still apply: Employers need to track whether each employee has received their required leave entitlement, even under an unlimited policy. Without clear records, it can be difficult to prove compliance.
    • Employees may take less leave: Unlimited leave does not always lead to more time off. Employees may take fewer days when there is no defined allowance, which can become a compliance issue where minimum leave must actually be provided.
    • Sick leave and public holidays may remain separate: In many countries, these are distinct legal entitlements with their own rules and cannot simply be included within one unlimited leave policy.
    • Unused leave can create payout issues: Unlimited policies often assume that no leave balance accrues, so there is nothing to pay when employment ends. Local law may treat statutory leave differently, particularly if the policy prevents employees from receiving or using their minimum entitlement.

    For global teams, accrual-based leave is often easier to manage in countries with statutory minimums, while unlimited or discretionary leave may be better suited to markets where local rules allow it.

    Manage global PTO with Boundless

    If you are employing people across borders and want every team member on a compliant leave entitlement, Boundless can act as the legal Employer of Record and apply the correct statutory rules in each market. Our team brings first-hand experience across 110+ countries and pricing that starts from €175 per month.

    Get in touch with our team to discuss your global team.

    FAQs

    Statutory annual leave runs from four weeks across the EU to no federal minimum in the United States. Sick leave and public holidays vary just as widely.

    Annual leave, sick leave and public holidays. In most countries, they are legally distinct entitlements with their own rules, funding and records, so they cannot be merged into one allowance.

    Only as a floor. A single policy can set a generous company-wide standard, but each market’s statutory minimum still applies on top, so entitlements have to be tracked country by country.

    It depends on the market. Statutory leave often has to be taken in the year it accrues, and in the EU it cannot lapse unless the employer warned the employee in time.

    In the EU, yes. Payment in lieu is barred during employment but required for any untaken balance on termination. Holiday pay is often valued above base salary.

    Only where no statutory minimum applies. Elsewhere you still have to show each person received their local floor, which means tracking a balance even when the policy does not cap one.

    The making available of information to you on this site by Boundless shall not create a legal, confidential or other relationship between you and Boundless and does not constitute the provision of legal, tax, commercial or other professional advice by Boundless. You acknowledge and agree that any information on this site has not been prepared with your specific circumstances in mind, may not be suitable for use in your business, and does not constitute advice intended for reliance. You assume all risk and liability that may result from any such reliance on the information and you should seek independent advice from a lawyer or tax professional in the relevant jurisdiction(s) before doing so.

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