Literature Review on Comparative Studies on Leave Policies and their Terminology Use

Autor(en)

, , , , , , , Gerlinde Mauerer, Sonja Dörfler-Bolt

Abstrakt

Executive summary
The COST Action ‘Parental Leave Policies & Social Sustainability’ (CA21150) focuses on enhancing and sharing knowledge about the role of paid parental leave (PPL) policies in fostering sustainable societies. The decision on terminology design for the PPL policies reflects values and expectations that pursue different goals in societies. As societies change, the terminology of parental leave policies also evolves.
Thus, WG4 of CA21150 provides a detailed exploration of recent developments in terminology, with a particular focus on the language used in leave policies. While the primary emphasis is on leave policies for parents of young children, it is important to note that other types of leave are becoming increasingly relevant. The report is divided into three main sections. The first examines the nomenclature used by international organisations with a focus on leave policies. The second looks at the terminology adopted by individual European countries, while the third reviews the language used in various comparative studies of leave policies. The concluding section reflects on whether a uniform or harmonised terminology for parenting leave policies for young children is desirable or feasible, and if so, what this terminology might entail.
Chapter 2 reviews official documents, databases, and policy frameworks to examine international leave terminology. Key sources include ILO conventions, EU directives, the OECD database and UN guidelines, alongside Leave Network research. The analysis identifies how organisations distinguish leave types—maternity, paternity, parental, and carer’s leave—while addressing health, caregiving, and gender equality. Legal instruments such as the 1992 EU Maternity Directive and the 2019 Work-Life Balance Directive set standards, complemented by softer recommendations such as the EU Care Strategy (2022). Despite progress, gaps remain, particularly in recognising the needs of parents of children with longer-term illnesses. The terminology not only informs regulations but also enables cross-national learning and monitoring, driving policy innovation and equitable leave access. This report identifies trends in international organizations towards the development of leave terminology naming new types of leave and design features, also creating umbrella terms referring to the whole leave package to facilitate international monitoring. It is also pointed out that children’s perspective is still held in a subordinate position at EU level, as leave policies are basically aimed at eligible mothers and eligible fathers.
Chapter 3 gathers and analyses as much as possible of the terminology used in 30 European countries, representing a variety of family policy systems. The analysis classifies PPL terminology as ‘role-focused’ if it refers to distinct roles (e.g., maternity, paternity or parental care), as ‘action-focused’ where it refers to actions such as care giving, upbringing, or education, and as ‘event-focused’ where the native term pertains to birth or pregnancy. Terminology of leave policies, including maternity, paternity and parental leave, is essential for policy comparison but often oversimplifies complex and diverse arrangements. Maternity leave, historically aimed at maternal health, now frequently encompasses broader caregiving roles and may include fathers and grandparents. Paternity leave definitions vary widely, sometimes allowing use long after childbirth. Parental leave, though broadly defined, masks significant differences in transferability and gender equality. The traditional tripartite classification is increasingly outdated, omitting types of leave such as ‘carer’s leave’ or ‘childcare leave’. Gender-specific terms are also being replaced by gender-
neutral ones, such as ‘ partner’s leave’ or ‘ birth leave’. Revisiting national terminologies could lead to more precise and inclusive international standards.
Chapter 4 provides a comparative analysis of how PPL terminology is handled by the academic community in their research findings. A total of 38 PPL comparative research articles were reviewed. Different choices of terminology are made in different studies in varying contexts, and to some extent these choices affect what is measured and therefore the results of the study. Authors focusing on aggregate measures, such as the length of leave or its effects, tend to use an umbrella term, usually ‘parental leave’, but sometimes self-defined terms. However, in studies that focus on the distribution of leave - usually between partners - such as those that focus on the transferability of leave, gender-specific terms are common, either in generic forms such as paternal or maternal leave, or in self-defined terms. It can therefore be seen that the choice of terminology plays a central role in influencing the research design and therefore the reported findings. However, explicit discussion of terminology choices is yet far from universal. Many papers in our sample do not discuss their terminology choices and their impact on the research design and results, and it can be assumed that at least some of them are not fully aware of these choices and their impact. A key conclusion, therefore, is that comparative leave studies should reflect in an open and explicit way on their terminological choices and their effect on the findings.
In sum, this report identifies new trends in international organizations towards a terminology that is more child-focused but often refers only to eligible parents. It also identifies a trend in the terms of PPL policies in some countries replacing gender specific terms by more gender-neutral ones, such as ‘partner’s leave’ or ‘birth leave’. Finally, it points out the lack of discussion on the terminology choices made by researchers on PPL when comparing PPL policies and their impact internationally.
The report concludes that while harmonizing terminology for leave policies within individual countries is neither necessary nor feasible, such harmonisation is crucial for presenting comparative information and conducting cross-country analyses. Standardized terms enable valid comparisons but must acknowledge the diverse values and assumptions underlying national policies. It is proposed that discussions should always include the original terms used in each country, both in English translations and in the local language, to preserve context and nuance. Finally, it is proposed that tables comparing countries drop attempts to show and compare ‘maternity leave’, ‘paternity leave’, ‘parental leave’ and ‘childcare leave’ or ‘homecare leave’. Instead, comparative tables should show aggregated results for ‘parenting leave’, divided into ‘mother only leave’, ‘father only leave’, ‘family leave’ and ‘total leave’.

Organisation(en)

Institut für Soziologie, Projekt: Familienforschung in Österreich

Externe Organisation(en)

Universidad Autónoma de Madrid, Ashkelon Academic College, Universitat de Barcelona, University of York, University College London, Universität Hamburg

Seiten

1-66

Anzahl der Seiten

66

DOI

https://doi.org/SocArXiv wkuam_v1

Publikationsdatum

04-2025

ÖFOS 2012

504001 Allgemeine Soziologie

Schlagwörter

Sustainable Development Goals

SDG 3 – Gesundheit und Wohlergehen, SDG 10 – Weniger Ungleichheiten, SDG 5 – Geschlechtergleichheit

Link zum Portal

https://ucrisportal.univie.ac.at/de/publications/b99805be-64a6-4df1-812d-8ad5927c26c0