An International Comparison and Assessment of Maternity Leave Legislation

Posted: 15 Jan 2003

See all articles by Kerstin Pull

Kerstin Pull

University of Tuebingen - School of Business and Economics

Dorothea Alewell

Friedrich-Schiller-University Jena


At present, we find legal provisions for maternity leave in almost every country. While these vary distinctly from country to country, their common and central feature is that they allow mothers to leave their workplace for a limited time around childbirth and to return to their jobs afterwards. This provision will typically impose costs on employers and affect the labor market situation of young women. However, there is no clear understanding about the nature and scope of these effects. Existing international comparisons typically include a large number of countries and only briefly review the regulations in place, concentrating on leave duration as a proxy for the costs of maternity leave imposed on the employer. In contrast, we compare maternity leave regulations in a limited number of countries in more detail (Denmark, Germany, the Netherlands, Japan, the U.S.A. and the U.K.), and we consider both, direct and indirect costs of maternity leave accruing to the employer. Concerning indirect costs, we distinguish the costs of human capital depreciation and the costs of re-organization: While the first will arguably rise with leave duration, the latter might be especially high for medium leave durations rendering work-sharing agreements problematic while not yet allowing for practicable replacement solutions. Furthermore, regulations affecting the predictability of leave duration will play an important role for the re-organization process and are consequently also included in the analysis.

Suggested Citation

Pull, Kerstin and Alewell, Dorothea, An International Comparison and Assessment of Maternity Leave Legislation. Comparative Labor Law & Policy Journal, Vol. 22, No. 2/3. Available at SSRN:

Kerstin Pull (Contact Author)

University of Tuebingen - School of Business and Economics ( email )

Nauklerstr. 47
Tuebingen, D-72074

Dorothea Alewell

Friedrich-Schiller-University Jena ( email )

Department of Economics & Business Administration
Carl-Zeiss-Str. 3
07743 Jena
+49-(0)3641-943130 (Phone)

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