Annual Leave Across the EU: A Country-by-Country Guide

If you're managing employees across more than one EU country, annual leave is one of the first places things get complicated. The EU sets a floor, but individual member states have added their own layers on top of it. What's generous in one country is the legal minimum in another.

This guide covers the EU baseline, then goes country by country for the ones most relevant to small businesses operating across Europe.

The EU Baseline: Working Time Directive

The EU Working Time Directive (2003/88/EC) gives every worker in the EU at least four weeks of paid annual leave per year. That's 20 days if you work a standard five-day week.

This is a floor, not a target. No EU country can legally offer less. Many offer considerably more.

A few things the Directive also covers:

• Leave cannot be replaced by a payment in lieu, except when the employment relationship ends.
• Workers must be able to take leave during the year it accrues. You can't simply roll everything over indefinitely.
• Leave must be "paid", meaning workers receive their normal remuneration during leave.

The tricky part is that "normal remuneration" has generated significant case law. The European Court of Justice has consistently ruled that commission, bonuses tied to attendance, and certain allowances should be included in holiday pay calculations. Many employers still get this wrong.

Country-by-Country Breakdown

Germany

Statutory minimum: 24 working days (Monday to Saturday)

This catches people out. Germany counts Saturday as a working day for leave purposes, so 24 days on a six-day week equals 20 days on a five-day week. For employees working a standard Monday-to-Friday schedule, the effective minimum is 20 days.

In practice, collective agreements (Tarifverträge) typically set entitlements at 25 to 30 days. Many white-collar employment contracts offer 28 to 30 days as standard.

Carry-over: In principle, leave must be taken in the calendar year it accrues. But the European Court of Justice (Kreuziger case, 2018) established that employers cannot simply let leave lapse without giving employees a genuine opportunity to take it. You need to actively remind employees and document it. Unused leave can carry over to 31 March of the following year if not taken, and some contracts allow longer carry-over periods.

Leave during illness: If an employee falls sick during annual leave, those days revert to sick leave. They don't lose their holiday entitlement.

France

Statutory minimum: 25 working days (5 weeks)

France uses "ouvrables" (working days including Saturday) or "ouvrés" (Monday to Friday only) depending on the contract. The standard is 2.5 days per month worked, accumulating to 30 ouvrables (or 25 ouvrés) per year.

RTT days: Employees covered by a 35-hour week agreement who work longer hours accumulate additional days called RTT (Réduction du Temps de Travail). In many office environments, this adds between 6 and 15 extra days per year on top of the statutory 25. The exact number depends on the collective agreement (convention collective) covering the business.

Leave year: France runs a reference period from 1 June to 31 May, which differs from most countries. Leave accrued in one reference period is meant to be taken by 31 May of the following year.

Public holidays: France has 11 national public holidays. Whether they're paid depends on the collective agreement and whether they fall on a working day.

Netherlands

Statutory minimum: 20 days (4 times weekly working hours)

Dutch law calculates leave as four times the number of days worked per week, so a standard five-day worker gets 20 days. Collective agreements (CAOs) typically push this to 24 to 25 days.

Carry-over: Statutory minimum leave (20 days) must be taken within 6 months of the end of the accrual year. Extra-statutory leave can be carried over for up to 5 years.

Holiday allowance: The Netherlands has a separate "vakantiegeld" (holiday allowance) requirement. Employers must pay an additional 8% of gross annual salary as a holiday allowance, usually paid out in May. This is separate from, and in addition to, normal salary during leave.

Long-term illness: Employees on long-term sick leave continue to accrue annual leave, which is a significant cost consideration. Leave accrued during illness must be paid out if the employment ends.

Belgium

Statutory minimum: 20 days

Belgium's leave system is more complex than most. Entitlement is based on the previous year's work (the "reference year"), so a new employee in their first year accrues leave to take the following year.

For blue-collar workers, the calculation and payment of holiday pay is handled centrally by a holiday fund (vakantiekas/caisse de vacances), not the employer directly. This catches many foreign employers off-guard when they first hire in Belgium.

Youth leave: Employees who didn't work the full reference year (recent graduates, for example) can apply for "European youth leave" to top up their entitlement in their first year.

Spain

Statutory minimum: 30 calendar days (22 working days)

Spain grants 30 calendar days, which works out to 22 working days on a standard week. Most collective agreements maintain this at 22 working days.

Leave in Spain is accrued monthly and must generally be taken in the calendar year. The employer and employee should agree on dates; if they can't, a court can determine them.

Illness during leave: As with Germany, Spanish employees who fall ill during annual leave can reclaim those days as sick leave.

Italy

Statutory minimum: 4 weeks

Italian law mandates 4 weeks of leave, and at least 2 of those weeks must be taken continuously during the year they accrue. The remaining 2 weeks can be spread across 18 months from the end of the accrual year.

Many collective agreements (CCNL) set entitlements at 20 to 26 working days depending on seniority and sector.

Poland

Statutory minimum: 20 or 26 days

Poland has a tiered system. Employees with less than 10 years of total employment history get 20 days. Employees with 10 or more years (cumulative across all employers) get 26 days. The calculation includes time in education.

Portugal

Statutory minimum: 22 working days

New employees accrue leave at 2 days per month in their first year. After that, the standard is 22 working days. Some contracts and collective agreements offer more.

On termination: Unused leave must be paid out on termination of employment, including leave accrued in the year of termination.

Sweden

Statutory minimum: 25 days

Sweden grants 25 days of annual leave under the Annual Leave Act (Semesterlagen). At least 4 of those weeks must be taken as a continuous summer holiday if the employee requests it.

Sweden also has a "saving" system where employees can carry over up to 5 days per year for up to 5 years, creating a reserve of up to 25 saved days. This is separate from the current year's entitlement.

Austria

Statutory minimum: 25 working days (30 after 25 years)

Austria grants 25 working days to start, rising to 30 working days after 25 years with the same employer. Collective agreements often add further entitlements.

Comparison Table

Practical Tips for Multi-Country Employers

Don't assume your home country's rules apply elsewhere. A 20-day entitlement that's generous in the Netherlands is the legal minimum in Sweden.

Check the collective agreement. In many EU countries, the relevant sectoral or company collective agreement sets terms above the statutory minimum. If you're bound by one, the statutory minimum is irrelevant.

Track by country. If you have employees in three countries, you need three sets of leave rules. Managing this in a single spreadsheet is manageable with two or three employees. It becomes unworkable as you grow.

Get country-specific advice for complex situations. Illness during leave, leave accrual during parental leave, and termination calculations all have country-specific rules that can catch you out. When in doubt, a local employment lawyer is worth the cost.

Tools like PersoHR let you configure leave rules per country so entitlements, carry-over limits, and accrual calculations are handled correctly regardless of where someone is based. It doesn't replace legal advice, but it reduces the administrative error rate significantly.

EU employment law evolves. The Working Time Directive is under review, and case law from the ECJ regularly adds new interpretations. Staying on top of this is part of the job of running a multi-country team.