Maternity, paternity, parental: three words, three statutes

By Skyler Bissell · August 8, 2026 · 8 min read

Berlin gives new parents 67 weeks of statutory paid leave, and they arrive from two different laws with two different names, only one of which means what an English speaker means by maternity leave. Get the words wrong and you will read a recruiter's benefits page as an offer of fourteen months at full pay, which is not what any of it says.

This is the most common misreading in relocation research, and it survives because English collapses three entitlements into words people use interchangeably. Every country that has all three keeps them apart in statute, pays them at different rates, attaches them to different people, and starts them on different dates. Here is each one, what it is worth at a real salary, and the three questions that make a headline week count mean anything.

The three terms, and who each one belongs to

Spain is worth knowing about because it dissolved the distinction on purpose. Since Real Decreto-ley 9/2025 there is no Spanish maternity leave and no Spanish paternity leave. Both parents hold one identical entitlement, the permiso por nacimiento y cuidado del menor, 19 weeks each, and the Estatuto de los Trabajadores says in terms that the right is individual and cannot be transferred to the other parent. That is how Madrid reaches 38 weeks: 19 doubled, with nothing shared and nothing gendered.

Why the German split decides real money

Take our published family household in Berlin: two earners, children aged 3 and 6, on €243,200, the euro equivalent of a $280,000 US household income. The engine values their statutory leave at €66,085, and every euro of that figure is Mutterschutz. Not one euro is Elterngeld.

The reason is an income test that applies to one of the two statutes and not the other. Elterngeld disappears entirely above a combined household income ceiling of €175,000, so all 53 of this household's Elterngeld weeks pay nothing. Mutterschutz has no such test and no ceiling on the employer top-up, so its weeks pay in full. Two words, two statutes, and for a well-paid household one of them is worth the entire figure and the other is worth zero.

Method note. The statutory ceiling is written against combined taxable income; our engine applies it against household gross, which is the conservative direction, since gross is always the larger number. For this household the two readings give the same answer, because a gross of €243,200 sits far enough above the ceiling that no plausible deduction brings it under.

Even under the ceiling the two are not interchangeable. Elterngeld pays 65% of prior income up to €1,800 a month, a cap that has not moved since the benefit was introduced in 2007. A Berlin engineer on a normal tech salary hits it immediately and the effective replacement rate collapses toward a fifth of pay. Mutterschutz pays full net. Anyone budgeting a German parental year on "65%" has mixed the two up in the direction that costs money.

Three choices behind every headline week count

Search for any country's parental leave and you will find three numbers. The disagreement is almost never about the law. It is about three unstated choices.

Are unpaid weeks counted? Britain is commonly reported at 52 weeks of maternity leave, which is true as job protection and false as income. Only 39 of those weeks carry Statutory Maternity Pay, so the last 13 are unpaid, and Britain arrives at 41 paid weeks once the 2 weeks of paternity pay are added and the unpaid tail is dropped.

One parent or both? Japan gives each parent leave until the child's first birthday and forbids transferring it, so a two-parent household holds two full spans and Tokyo's 110 weeks is the honest household figure. Report the same country per parent and you get 58. Both numbers are defensible; only one of them can sit in a column next to Sweden's.

Shared pot counted once or twice? Sweden's 480 days are one pot for the household, with 90 days reserved for each parent inside it. Counting the pot twice would produce a fictional 960 days. Norway's 49 weeks work the same way: a modrekvote, a fedrekvote and a shared fellesperiode, all inside one family entitlement.

cityparity states its own answers rather than leaving them implicit. Every statutory paid week around one birth counts, each parent's non-transferable entitlement is summed, a shared pot is counted once, and unpaid or conditional weeks are excluded. That basis is applied identically to all 70 countries in the dataset, and it is why a few of our numbers sit below the ones you will see elsewhere. The country-by-country result is ranked at parental leave by country.

What the words are worth at one household income

Weeks are the wrong unit for a decision, because a week at a flat state minimum and a week at full pay are the same week and different money. Here is the same household, two earners with two children, run through the engine city by city. Each figure is weeks times the effective replacement rate at that household's income, so a generous cap and a stingy one separate.

• Berlin, Germany: 67 statutory paid weeks worth €66,085, all of it maternity protection at this income.
• Stockholm, Sweden: 70 weeks worth SEK 519,801, the equivalent of $54,658. The longest entitlement in this list and a payout ceiling of SEK 8,813 a week that binds long before a tech salary.
• Tokyo, Japan: 110 weeks worth $47,826. Two non-transferable per-parent spans, which is the only way a rich country reaches a three-figure week count.
• Amsterdam, Netherlands: 40 weeks worth €46,980, on a capped percentage that runs closer to full pay than the German or Swedish equivalent.
• Madrid, Spain: 38 weeks worth €44,734, paid at 100% of a contribution base capped at €5,101 a month.
• Copenhagen, Denmark: 52 weeks worth the equivalent of $40,869, on a flat weekly maximum that any professional salary clears.
• London, UK: 41 paid weeks worth £28,401, held down by 35 weeks at the flat £194 rate.
• Seattle, US: 24 weeks worth $39,528, which is a state programme rather than a national one and is the best any American city in our dataset manages after Portland.
• Austin, US: 0 weeks and $0, because Texas runs no paid programme and the federal entitlement is unpaid.

Read the Berlin and Stockholm rows against each other and the vocabulary stops being pedantry. Sweden has three more weeks than Germany on paper and a lower valuation at this income, because almost all of Sweden's weeks sit under a payout ceiling while a chunk of Germany's sit under an employer top-up obligation instead. The word attached to a week tells you which rule it obeys.

Four phrases that mean less than they sound like

"Up to 12 months." Almost always a duration of job protection with a shorter paid window inside it. Ask how many of the months carry a payment and at what rate.

"Shared parental leave." In Britain this reallocates the mother's untaken maternity weeks to the other parent. It moves weeks between people and creates none, so it never raises the household total.

"The daddy quota." A reserved block the household forfeits if the second parent does not take it. Norway invented it, Sweden reserves 90 days per parent, and Germany's 14-month pot is 12 months plus 2 Partnermonate that exist only if both parents take leave. A quota makes a headline number unreachable by one parent working alone.

"Family leave." An American term covering a different thing entirely: unpaid job protection under federal law, with a paid benefit only where a state has built one. What that gap costs a US household, and which eleven of our twenty-eight US metros sit in a state that pays anything, is worked through in is FMLA paid or unpaid.

FAQ

What is the difference between parental leave and paternity leave?

Paternity leave is short, attached to the second parent, and taken around the birth itself: 2 weeks in Britain, about 1.4 weeks in Sweden, and it exists to get one parent home in the first fortnight. Parental leave is the long entitlement for raising the child, open to either parent, and it runs from 38 weeks in Spain to 110 weeks in Japan. Paternity leave sits inside the days after a birth. Parental leave sits inside the first year or three of a child's life.

Is maternity leave the same as parental leave?

In most of Europe, no. Maternity leave is health protection attached to the person who gave birth, it usually starts before the due date, part of it is compulsory, and it usually pays better than the parental leave that follows. Germany keeps them in two different statutes: Mutterschutz sits in the MuSchG at full net pay with no ceiling, Elterngeld sits in the BEEG at 65% capped at €1,800 a month. Spain is the counter-example, having abolished the distinction: both parents hold the identical non-transferable entitlement of 19 weeks each.

Why do countries report such different parental leave numbers?

Because three choices sit behind every headline and nobody states them. Whether unpaid weeks are counted, whether both parents' entitlements are summed or only one parent's, and whether a shared pot is counted once or twice. cityparity uses one basis for all 70 countries: every statutory paid week around one birth, summing each parent's non-transferable entitlement and counting a shared pot once. Britain drops from 52 to 41 under that rule, because 13 weeks of the maternity year are unpaid.

What is the daddy quota?

A block of parental leave reserved for the second parent that the household loses if he does not take it. Norway invented the idea and splits its 49 weeks into a modrekvote, a fedrekvote and a shared fellesperiode. Sweden reserves 90 of its 480 days for each parent on the same logic, and Germany's 14-month Elterngeld pot is 12 months plus 2 Partnermonate that only exist if the second parent takes them. The quota is a use-it-or-lose-it design, and it is why a country's headline number can be unreachable by one parent alone.

The practical version of all this is one question to put to any recruiter, in writing: how many weeks carry a payment, at what percentage, up to what ceiling, and which of them are reserved for the other parent. Four answers, and they turn a benefits page into a number. What that number does to a whole relocation is priced across every dimension at New York vs Berlin for a family and Seattle vs Stockholm for a family, or put your own household through the calculator. The wider case for valuing time off in currency instead of days is in the hidden paycheck.

Sources. German rules: MuSchG section 3 for the Mutterschutz periods and BEEG section 2 for the Elterngeld rate and cap. Swedish rules: Forsakringskassan. British rules: gov.uk Statutory Maternity Pay and Statutory Paternity Pay. Spanish rules: Real Decreto-ley 9/2025 amending Estatuto de los Trabajadores article 48.4. Norwegian quotas: NAV. Japanese rules: the Ministry of Health, Labour and Welfare. Cross-country context: the OECD Family Database. Week counts and valuations are computed by cityparity's per-city engine; per-field provenance is in data/_meta.json.

Statutory rates and ceilings move; treat the figures as current at publication. See the methodology.