Compare the different benefits offered to parents in the UK and France.
In the UK
Statutory Maternity Leave
Women are entitled to 26 weeks off, regardless of how long they have worked for their employer. Statutory Maternity Pay (SMP) is paid for 26 weeks. For the first six weeks SMP is paid at 90% of average earnings and for the remaining 20 weeks SMP is £108 a week or 90% of average weekly earnings if this is less. The government has pledged that from 2007, paid maternity leave will be extended from six to nine months, worth an estimated extra £1,400.
Additional Maternity Leave
Women can take another 26 weeks of additional maternity leave if they meet certain eligibility criteria. They must have completed 26 weeks continuous service with their employer by the beginning of the fourteenth week before their expected week of childbirth. Additional maternity leave is usually unpaid, but some companies will contribute.
Fathers have the right to two weeks' paid paternity leave at present. Fathers will get a £108 a week or 90% of their average weekly earnings if this is less, for two weeks, known as Statutory Paternity Pay (SPP). It can be taken from the date of birth or up to eight weeks from the birth. To qualify, the man must have worked for his employer for 26 weeks by the fifteenth week before the baby is due and earn more than £79 a week. He must notify his employer of the date he wants to start paternity leave in the fifteenth week before the baby is due.
Child Tax Credit
Nine out of ten families with children can get tax credits. Child Tax Credit is a means-tested allowance for parents and carers of children or young people who are still in full-time education. All families with children can claim Child Tax Credit if their income is no more than £58,000 a year (up to £66,000 if you have a child under one). You don't have to be the child's parent to be eligible, but you must be the main person who's responsible for them. The amount you get depends on various things, including your annual income. The payment is made up of two elements:
- Family element paid to any family with at least one child and worth up to £545 (2005-2006 tax year)
- Child element paid for each child in the family and worth up to £1,690 (2005-2006 tax year).You may get more if you care for a child under one or a disabled child.
The other tax credit parents may be entitled to, if either one of them is working is called Working Tax Credit, and this includes a childcare element to help families who are working and spending money on childcare.
Parents of children aged under six or disabled children aged under 18 have the right to apply to work flexibly and their employers will have a duty to consider these requests seriously. The right enables mothers and fathers to request to work flexibly. It does not provide an automatic right to work flexibly as there will always be circumstances when the employer is unable to accommodate the employee's desired work pattern.
Anyone who has completed one year's service with an employer is entitled to 13 weeks' (unpaid) parental leave to care for their child. Parental leave can usually be taken up to five years from the date of birth or in cases of adoption five years from the date of placement (or the child's eighteenth birthday, if that is sooner). Parents of disabled children are entitled to 18 weeks' parental leave (previously 13 weeks) up to the child's eighteenth birthday, providing they have the qualifying length of service. All employees are also entitled to take a reasonable amount of (unpaid) time off work to deal with an emergency or unexpected situation involving a dependant.
Maternity leave and parental leave
France offers all women workers a paid, job -protected maternity leave six weeks before and 10 weeks after the births of the first two children, eight weeks before and 18 weeks after the birth of the third child, 34 weeks (12 prenatally) for twins and 42 weeks (24 prenatally) for triplets or more. Maternity leave, pre and postnatally, is mandatory.
At the end of maternity leave, the mother or father can take parental leave until the child reaches the age of three, with entitlement to re-integration into the previous or a similar job. Parents receive a parental leave allowance if they interrupt their employment, totally.
Child Benefits and Family Allowances
All families with at least two children under 18 are granted family allowances. The following additional means-tested benefits are available:
- Family supplement for families with at least three children over three years of age
- Single parent allowance
- Adoption allowance paid only for 21 months
- Parental education allowance
- Special education allowance. Depending on the level of the child's handicap, a further sum is available
- Annual school allowance for children aged six to 18
- Housing allowance which is calculated taking into account expenses for rent and the family's situation.
A means-tested, young child allowance is available from the fourth month of pregnancy until a child is three. Maternity benefit, the benefit paid during the maternity leave, equals the net salary up to a certain threshold. Maternity benefits for insured mothers amount to 80 percent of earnings for up to 16 weeks for the first and second child, 26 weeks for subsequent children, and 46 weeks for multiple births (a number of collective agreements allow for an additional 20 percent payment during the same period).
Younger children are entitled to places in full-day childcare centres and sometimes family day care. Beginning at ages two or three, children are served in full-day preschool programmes, the écoles maternelles, for which families pay on a sliding scale. Lower-income families usually pay nothing and better-off families pay no more than 10 to 15 percent of their income for this service. Nearly all children enrol in écoles maternelles, even if they have a parent at home, because the French believe that these nursery schools are important in preparing the vocabulary and communication skills of young children for the social and academic rigours of the first grade. France also offers allowances to defray the costs of hiring childcare, at home or in registered facilities, for children under three.
One of the distinguishing characteristics of the French family policy is its systematic focus on supporting the arrival of the third child. In France, the amount paid for the third child and subsequent children is greater, and no allowance is paid for the first child.
Balancing Employment and the Family
French family policy shows a more comprehensive commitment to offering choices to all working mothers than many other European countries. The French have never set out, in the way that other countries have, to restore the place of women in the home. The first paid maternity leave was introduced in 1913, and public childcare is more affordable and widely available than in many other countries. In addition, France offers generous family allowances and parental leave benefits that were conceived as a replacement for foregone wages rather than as wages for motherhood, as is the case in Germany. A relatively high proportion of French women work full-time, especially single mothers, in large part because they have access to high-quality, state-run, subsidised childcare. In France, 25 percent of children aged two or younger, and 95 percent of three to five year olds, are in public childcare. In 1995, nearly 80 percent of women between 25 and 39 (those most likely to be in their childbearing years) were employed.