Annual Leave Entitlements: All 7 Countries Compared 2026

Last verified: 2026-05-02

Statutory paid leave is one of the largest single drivers of employer cost-of-employment. France’s 5 weeks plus 11 public holidays is more than double the US median. The UK’s 5.6 weeks (28 days) including bank holidays differs structurally from Australia’s 4 weeks plus public holidays. This guide compares all seven jurisdictions for 2026 with statute citations and worked examples.

Quick Answer (TL;DR)

• Most generous: France (5 weeks + 11 public holidays + RTT days for cadres au forfait).
• Anglosphere middle: UK (28 days incl. 8 bank holidays), Ireland (similar), Australia (4 weeks + public holidays + 17.5% leave loading in some Awards), NZ (4 weeks + 11 public holidays).
• Lowest mandatory: US (zero federal), Canada Ontario (2 weeks initial / 3 weeks at 5+ years).
• 17.5% leave loading: Australia under many Modern Awards adds a 17.5% premium when leave is taken.

Comparison Table at a Glance

Country-by-Country Deep Dive

France — 5 Weeks + Public Holidays + RTT

Statute: Code du travail L.3141-3.

“Le salarié a droit à un congé de deux jours et demi ouvrables par mois de travail effectif chez le même employeur.”

That is 2.5 jours ouvrables (Mon–Sat) per month of work, totalling 30 jours ouvrables = 5 jours ouvrés × 5 weeks = 25 working days of annual leave.

Public holidays (jours fériés): 11 nationally. Of these, only Labour Day (1 May) is mandatorily paid + double-pay if worked (L.3133-4). The other 10 are by Code default unpaid if worked (most CCNs make them paid).

RTT (Réduction du Temps de Travail): for employees on forfait annuel working >35 hours/week, additional days off to compensate. Typical 8–12 RTT days for cadres on 39-hour forfait.

Total typical employee: 25 + 11 + 0–12 = 36–48 days off per year.

Source: https://www.legifrance.gouv.fr/codes/section_lc/LEGITEXT000006072050/LEGISCTA000006177897/

United Kingdom — 5.6 Weeks Including Bank Holidays

Statute: Working Time Regulations 1998 (SI 1998/1833), reg 13 + 13A.

UK statutory minimum:

• Reg 13: 4 weeks (20 days for full-time on 5-day week).
• Reg 13A: additional 1.6 weeks (8 days for full-time).
• Total: 5.6 weeks = 28 days for a full-time 5-day employee.

Bank holidays included. Unlike Australia, UK statutory leave includes the 8 bank holidays. An employer may choose to include them in the 28 days (most do) or grant them on top.

Pro rata for part-time (Reg 13(7)): 28 × (days worked / 5).

Carry-over: WTR allows up to 8 days of reg 13 leave to carry over by agreement; reg 13A leave cannot be carried.

Source: https://www.legislation.gov.uk/uksi/1998/1833/regulation/13

Australia — 4 Weeks + Public Holidays + 17.5% Loading

Statute: Fair Work Act 2009 s.87 (annual leave); s.114 (public holidays).

NES floor:

• 4 weeks paid leave per year (s.87(1)) — pro-rated for part-time.
• 5 weeks for shift workers (s.87(1)(b)).
• 7 national public holidays (s.115) + state-specific.

17.5% leave loading. Many Modern Awards (e.g., Manufacturing & Associated Industries Award, Hospitality Industry Award) require employer to pay 17.5% premium on top of base pay when annual leave is taken.

Cashing out (s.93): allowed only via written agreement; minimum 4 weeks must remain accrued.

Source: https://www.fairwork.gov.au/leave/annual-leave

New Zealand — 4 Weeks + 11 Public Holidays

Statute: Holidays Act 2003 ss.16–25 (annual holidays); s.43 (public holidays).

• 4 weeks annual holidays after 12 months continuous employment.
• 11 public holidays (paid if otherwise worked).
• Pay rate: greater of (a) ordinary weekly pay, (b) average weekly earnings over 4 weeks, (c) average weekly earnings over 12 months.

Cashing out (s.28A): up to 1 week per year, by written request; remaining 3 weeks must be taken as leave.

Source: https://www.employment.govt.nz/leave-and-holidays/annual-holidays/

Canada (Ontario) — Tiered

Statute: Employment Standards Act 2000 s.33, s.34.

• 2 weeks annual leave for first 5 years (s.33).
• 3 weeks after 5 years’ service (s.34).
• Vacation pay 4% of gross wages (or 6% after 5 years) — paid even when leave is not taken.
• 9 public holidays (s.24).

Federal sector (Canada Labour Code) provides 3 weeks initially, 4 weeks after 5 years, 5 weeks after 10 years.

Source: https://www.ontario.ca/document/your-guide-employment-standards-act-0/vacation

United States — Zero Federal Floor

Statute: Fair Labor Standards Act 1938 (FLSA, no leave provision).

The US has no federal mandate for paid annual leave. Some states have:

• No state minimum in most states.
• Local paid sick leave ordinances: NYC, San Francisco, Seattle, DC, Massachusetts.

Employer-provided vacation (typical 10–15 days for office workers) is contractual, not statutory.

Federal employees receive 13–26 days/year by GS step.

Source: https://www.dol.gov/

Decision Framework / Q&A

Q1: I’m hiring my first French employee. How many days off do I budget?

Plan for ~5 weeks annual leave + 11 public holidays + 8 RTT days for a cadre on forfait = ~44 days/year. Assume the employee will take all of them.

Q2: UK 28 days — does that include bank holidays?

By statute, the 28 days can be inclusive of bank holidays. Most contracts state “20 days plus bank holidays” (which equals 28). Some contracts specify “28 days inclusive of bank holidays” — the latter means an employee who works on a bank holiday gets a day in lieu, no extra entitlement.

Q3: Australian leave loading 17.5% — universal?

No. It applies only when a Modern Award imposes it. Award-free employees and employees on enterprise agreements without loading do not receive 17.5%.

Q4: NZ 4 weeks vs Australia 4 weeks — same?

Numerically yes, but NZ public holidays are 11 vs Australia 7 national + state add-ons (~10–12 depending on state). Net annual paid time off is similar.

Q5: Why does the US have no federal annual leave?

Federal politics. The Family Medical Leave Act 1993 was a major federal expansion but covers only unpaid leave for medical/family reasons. Several federal paid-leave bills have been proposed and not passed.

Common Pitfalls (Gyoseishoshi View)

1. France: assuming jours ouvrables (Mon–Sat) = jours ouvrés (Mon–Fri). Convert correctly: 30 jours ouvrables = 25 jours ouvrés.

2. UK: paying out reg 13A leave on termination at the wrong rate. Reg 13A leave must be paid at the same rate as reg 13.

3. Australia: forgetting 17.5% loading in payroll for Award-covered employees on annual leave.

4. NZ: averaging holiday pay incorrectly under Holidays Act s.16. The Act has been long-criticised as confusing; a Holidays Act reform is in progress (consultation 2024–25).

5. Ontario: failing to pay vacation pay 4% even on hourly casual workers — vacation pay must accrue regardless of formality.

6. US: terminating an employee with accrued vacation in California without paying it out — California Labor Code §227.3 treats vacation as wages owed at termination.

Conclusion

Annual leave is the highest-variance HR cost across the seven jurisdictions. France leads at ~36–48 total days off, the US is at zero federal floor, and most others cluster at 24–31 days. Always model total off days including public holidays when budgeting headcount cost.

MmowW Scrib🐮 generates compliant employment agreements with the correct annual leave entitlement (jours ouvrables vs ouvrés in France, NES + Award loading in Australia, Holidays Act formula in NZ) for each jurisdiction.

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Disclaimer

Legal information, not legal advice. MmowW Scrib🐮 is operated by a licensed Gyoseishoshi (行政書士) office in Japan. We are not solicitors, barristers, attorneys, avocats, or licensed legal practitioners in any jurisdiction.

Sources

• France Code du travail L.3141-3: https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000037385648
• France service-public congés: https://www.service-public.fr/particuliers/vosdroits/F2258
• UK Working Time Regulations 1998: https://www.legislation.gov.uk/uksi/1998/1833
• UK GOV.UK holiday entitlement: https://www.gov.uk/holiday-entitlement-rights
• Australia Fair Work s.87: https://www.legislation.gov.au/Details/C2024C00194
• Australia Fair Work annual leave: https://www.fairwork.gov.au/leave/annual-leave
• New Zealand Holidays Act 2003: https://www.legislation.govt.nz/act/public/2003/0129/
• New Zealand employment.govt.nz: https://www.employment.govt.nz/leave-and-holidays/annual-holidays/
• Canada Ontario ESA s.33/34: https://www.ontario.ca/laws/statute/00e41
• US DOL leave: https://www.dol.gov/general/topic/benefits-leave