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Comparison ยท Benefits October 2026 · 4 min read

Sick Pay Across 22 Systems: Who Pays and For How Long

Nobody negotiates a job offer on sick pay and almost everybody eventually needs it. The variation between countries is larger than the variation in salary.

Sick Pay Across 22 Systems: Who Pays and For How Long

Sick pay is the part of an employment package that nobody examines until it is needed. It is also, measured in money, one of the largest differences between working in one country and another. A long illness in the Netherlands is a manageable financial event. The same illness in a country with no statutory provision is not.

Who carries the cost

Three models exist, and they allocate the burden differently between employer, state and employee.

  • Employer liability. The Netherlands is the extreme case, with employers required to continue paying a substantial share of salary for up to two years, together with reintegration obligations. Germany requires six weeks at full pay before the health insurance fund takes over.
  • State insurance. Most of Scandinavia, France, Italy and Spain pay sickness benefit through the social insurance system after a short employer period or a waiting period.
  • Statutory minimum plus employer discretion. The United Kingdom and Ireland set a low statutory floor and leave the rest to contract. What you actually receive depends almost entirely on your employer's policy.
Country Statutory position Practical outcome
Netherlands Employer pays at least 70% of salary for up to 104 weeks The most protective system in Europe, and a significant employer cost
Germany Employer pays full salary for six weeks, then Krankengeld from the health fund Krankengeld is around 70% of gross, capped, for up to 78 weeks
Sweden One qualifying day, then employer sick pay for two weeks, then state benefit Collective agreements frequently top up
Denmark Employer pays for an initial period, then municipal benefit Benefit is capped at a weekly maximum
France Social security daily allowance after a waiting period, employer top-up by law after seniority Combined effect approaches full pay for established employees
Italy INPS indemnity at a rising percentage by duration, employer integration common Sector agreements matter a great deal
Spain Reduced percentage for early days, rising thereafter Employer covers part of the early period
United Kingdom Statutory Sick Pay at a flat weekly amount for up to 28 weeks Low enough that occupational sick pay is the real entitlement
Ireland A statutory sick pay scheme phased in, otherwise Illness Benefit Employer schemes remain decisive
United States No federal entitlement, some state and city mandates Employer policy and short term disability insurance

What to ask about in an offer

Because the statutory floor varies so much, the question that matters is what the employer adds on top of it. In the UK and Ireland this is the single most valuable and least discussed contract term.

  1. How many weeks at full pay, and how many at half pay.
  2. Whether entitlement increases with service, which is the usual pattern.
  3. Whether there is a waiting period before occupational sick pay starts.
  4. Whether income protection insurance is provided, which typically pays a percentage of salary after a deferral period of three or six months and is the real safety net for long illness.
  5. Whether pension contributions continue during sick leave.

How sick pay is taxed

Employer paid sick pay is salary and is taxed as salary, including social contributions, in essentially every system. State sickness benefit is more varied.

  • German Krankengeld is not directly taxed but is included under the Progressionsvorbehalt, raising the rate on other income for the year.
  • UK Statutory Sick Pay is taxable and subject to National Insurance, because it is paid through payroll.
  • Scandinavian sickness benefits are ordinary taxable income.
  • Payments from a private income protection policy are usually taxable where the employer paid the premium and tax free where you paid it from taxed income. This is a genuinely important distinction and it is frequently not explained.

The Dutch system deserves its own note

Two years of employer funded sick pay is unique in scale, and it changes hiring behaviour. Dutch employers carry substantial insurance against it, they take the reintegration obligation seriously because the state can extend the liability if they do not, and probationary periods and fixed term contracts are used more cautiously than elsewhere.

For an employee it is an unusually strong protection. For anyone comparing a Dutch offer with one elsewhere, it is a real part of the package that will never appear in a salary comparison.

Related: Finland Tax Card

Written by OฤŸuz Yasin BaลŸ · last updated 18 Oct 2026

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