REPORT OF ACCOUNTING AND
PAYMENT OF HOLIDAY MONEY
IN EUROPEAN COUNTRIES
2019
Report of: AUSTRIA, CROATIA, GERMANY, IRELAND, ITALY, LUXEMBURG, SLOVENIA, CZECH REPUBLIC, ESTONIA, FINLAND, IRELAND, POLAND, UNITED KINGDOM
WOLFGANG KATZMANN
1
Content Austria ...................................................................................................................................................... 4
Results for Austria ................................................................................................................................ 5
Croatia...................................................................................................................................................... 6
Results for Croatia ............................................................................................................................... 6
Germany .................................................................................................................................................. 8
Results for Germany ............................................................................................................................ 8
Ireland .................................................................................................................................................... 10
Results for Ireland .............................................................................................................................. 11
Italy ........................................................................................................................................................ 12
Result for Italy .................................................................................................................................... 12
Luxemburg ............................................................................................................................................. 14
Result for Luxemburg ......................................................................................................................... 14
Slovenia .................................................................................................................................................. 15
Result for Slovenia ............................................................................................................................. 15
Czech Republic ....................................................................................................................................... 16
Results for Czech Republic ................................................................................................................ 17
ESTONIA ................................................................................................................................................. 17
Results for Estonia ............................................................................................................................. 18
FINLAND ................................................................................................................................................. 19
Results for Finland ............................................................................................................................. 19
POLAND .................................................................................................................................................. 20
Results for Poland.............................................................................................................................. 21
UNITED KINGDOM .................................................................................................................................. 22
Results for United Kingdom .............................................................................................................. 22
Summary of Results .............................................................................................................................. 264
Conclusion ............................................................................................................................................ 286
Literature ............................................................................................................................................. 297
2
Table
Table 1 Employees in the public Sector .................................................................................................. 3
Table 2 Result of Austria ......................................................................................................................... 4
Table 3 Result of Croatia ......................................................................................................................... 6
Table 4 Result of Germany ...................................................................................................................... 7
Table 5 Public Sector in Ireland ............................................................................................................... 8
Table 6 Result of Ireland .......................................................................................................................... 9
Table 7 Result of Italy ............................................................................................................................ 11
Table 8 Result of Luxemburg ................................................................................................................. 12
Table 9 Minimum wage 2013-2017 ....................................................................................................... 13
Table 10 Result of Slovenia ................................................................................................................... 14
Table 11 Summary of Results ................................................................................................................ 15
Purpose of the document
The purpose of this paper is to research and report in the fields of accounting and payment methods
of holiday pay in various European countries in order to document the different practices of
payments in European Union countries in the public sector.
Methods
• Research of well-known resources;
• Official governmental sites and verified literature (see list of references);
• Based on the collective law for the public sector per country;
• Legal regulations quoted and documented.
Introduction
Lithuania has requested technical support from the European Commission under the SRSP scheme in the field of “Improving the back-office functions of the public sector”. Under the implementation of the large-scale reform programme “Enhancement of the efficiency of the public sector”, this research report refers to the “consolidation of back office functions”.
In Lithuania the holiday money paymentsare done in advance of the holidays, should it be asked for by the employee to get the holiday pay earlier as his regular salary.
In order to document how other European countries are dealing with this subject it is required to document how accounting and payments of holiday pay is handled in the public sector of the European countries.
3
Reported Countries
In order to get a representative on how holiday pays are paid to employees in Europe, the
following countries are to be looked at in this report: i
AUSTRIA
CROATIA
GERMANY
IRELAND
ITALY
LUXEMBURG
SLOVENIA
CZECH REPUBLIC
ESTONIA
FINLAND
IRELAND
POLAND
UNITED KINGDOM
4
Austria The current population of Austria is 8.773 million according to the EUROSTAT European Statistics
(European Commission, Eurostat 2018). Around 15.9% are working in the public sector. The
following table shows a a comparison between European countries for employees working in the
public sector (OECD, Government at a Glance OECD 2017 2017).
Table 1 Employees in the public Sector
Public administration in Austria is carried out on three levels: the Federal level, the level of the nine
lands (), and that of 2,099 municipalities. In addition, social insurance funds, statutory representative
bodies (called “Chambers”, e. g. the Chamber of Labour or the Chamber of Commerce), and other
legal entities involved in providing public services are sometimes included in the definition of the
public sector. The Federal Civil Service is composed by the Federal Ministries—headquartersas well
as subordinate bodies—which are responsible for carrying out the administrative tasks of the
Federation (or Bund, as it is called in Austria). Only 8% of Federal civil servants work in the Federal
Ministries themselves, while 91% work in their numerous subordinate bodies, such as schools,
courts, tax offices and police stations. Finally, 1% of all Federal civil servants work for the Federal
President's Office, the Parliamentary Administration, the Constitutional Court, the Supreme
Administrative Court, the Ombudsman Board and the Court of Audit, which are collectively known as
the “supreme institutions” of the Republic (Federal Chancellery of Austria 2017).
5
Employees and apprentices have a minimum entitlement of five weeks payed annual leave. In terms
of working days, one is entitled to 30 days’ leave or 25 working days, which includes Saturdays, in
each working year. In addition to their monthly payment, employees in Austria also receive a holiday
bonus, known as the 14th monthly pay cheque or holiday pay. Employees must come to an
agreement with their employer when they may take their leave; the employer must give his/her
consent (European Commission, EURES 2018).
Every quarter of the year according to art. 7. 2 and 7.3 for public officials of the salary law (Gehaltsgesetz) and to art. 8a of the contracted servant act (Vertragsbedienstetengesetz) there is a holiday pay to the officials in the amount of 50% of the monthly salary. This amount is paid in addition to and together with the monthly salary. It is paid on pre-defined dates, i.e 1st of march (for the first quarter), 1st of June (for the second quarter), 1st of September (for the third quarter) and 1st of December (for the fourth quarter).
The contracted staff gets the holiday pay on the 15th of February (for the first quarter), on the 15th of May (for the second quarter), on the 15th of August (for the third quarter) and on 15th of November (for the fourth quarter).
Results for Austria
Is “holiday pay” in your country paid separately
No
from the salary and if yes, what kind of legal act
oblige that?
Is ”holiday pay” in your country paid in advance
No
of the holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Table 2 Result for Austria
Conclusion
The “Holiday pay” is fully integrated in the monthly salary for all officials on state level in Austria.
6
Croatia The current population of Croatia is 4.152million, based on the latest United Nations estimates (Worldometers 2019).
Comparative analysis shows that most indicators imply that the Croatian public sector is not too big, except for the share of public enterprises' employees in total employment. The share of the general government budget expenditures for compensation of employees in GDP in Croatia is lower than the average share of EU countries, but it was a little higher than the average share of countries of Central and Eastern Europe over the first three years of the observed period. The share of total general government expenditures in GDP in Croatia is lower than the corresponding shares in EU and Central and Eastern European countries. (Bejakovic 2017)
Salary is paid monthly after completion of the work, and no later than the fifteenth day of the following month and is usually paid to the employee’s bank account. For difficult working conditions, overtime and night work, and work on Sundays, holidays and other days which the law provides for rest, the employee is entitled to increased pay. It is a common practice to obtain an annual 0.5% rise for each year of work (usually set down in the collective agreement). Some employers add a transport allowance (non-taxable) to the wage and some also pay a hot meal allowance (included in the salary and taxable). Employees are eligible to be paid annual leave of at least four weeks in a calendar year. Longer annual leave may be determined by a collective agreement, work regulation or a work contract. Public holidays are not included in the duration of the annual leave (EURES Croatian Employment Service 2018)
In Croatia “holiday pay can be paid separately from the salary. The holiday pay is not considered as a salary, it is another material right and regulated in art 59 (1) Collective agreement for public servants / art 83. Labour law.
The “holiday pay” must be paid at least 15th of July (art 59. (3) CA for public servants)
It can be paid afterwards because the employees have the right to get paid after the 15th of July, if they weren’t there to get paid in cases which are listed in the collective agreement. Then they can get their “holiday pay” at least 7 days before using their vacation. (art 59 (3) CA for public servants). In article 59 (2) CA for public servants it says how much “holiday pay” the servants should get. The amount of the “holiday pay” is decided with agreement between the government and the syndicate of public servants each year.
In Croatia, the law does not provide for the possibility that “holiday pay” is paid in advance of
holiday or (if such possibility exists) separately from the salary.
Results for Croatia Is “holiday pay” in your country accounted separately from the salary and if yes, what kind of legal act oblige that?
Yes, Collective Agreement of public servants
Is ”holiday pay” in your country paid in advance of the holiday (or if such a possibility exists) separately from the salary and if yes, what kind of legal act oblige that; If there is just a ssibility, please describe the conditions, on which such possibility could be implemented.
The holiday money must be paid on July 15th the latest of each year in general
Table 3 Result for Croatia
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Conclusion
In the Croatian legal system there is a special payment for public servants. They have the right to a
holiday pay before the 15th of July for the vacation. The holiday money is paid separately from the
salary and is not considered as a part of the wage. It is a special type of material right, which belongs
to the public servants. The amount of the “holiday money” will be renewed in discussion between government and syndicate of the public servants.
8
Germany Germany has a population of 89.79 million inhabitants. Around 1.67 millions are employed in the public sector, on the state level as well as on the country level (VKA-BUND.DE).
Since 2008, civil servants have not received any holiday pay (in other words the term “Urlaubsgeld” was removed and the term “Sonderzahlung” (Special payment) has been used ever since.(Beamten Darlehen 2018). Special payment can be paid once at the end of the year or monthly. This depends on the level of public organization (State or local) where the servant works.
The amount and the way of payment are declared in the collective agreement for the public service “Tarifvertrag für den Öffentlichen Dienst” (TVöD) and collective agreement for the public service of the countries “Tarifvertrags für den öffentlichen Dienst der Länder” (TV-L). Every two years this legal document is brought in agreement between the public servants as employees and the government as employer.
With the ”Law on the reorganisation and modernisation of federal civil service” - “Dienstrechtsneuordnungsgesetz” the German government declared that from the 1st of July the special payment for all state servants will be integrated in the regular salary (Sonderzahlungen Anwalt 24 2018).
The countries can individually decide, if special payment for their employees is integrated in the salary or paid seperately before a holiday. For example the country Nordrhein-Westfalen integrates the special payment to the regular salary and is also paid the same day as on state level. In the country Bavaria (Bayern) it will be paid once a year before Christmas (Sonderzahlungen Anwalt 24 2018).
Results for Germany
Is “holiday pay” in your country accounted
separately from the salary and if yes, what kind
No (it is integrated on the state level).
of legal act oblige that?
Is ”holiday pay” in your country paid in advance
of the holiday (or if such a possibility exists)
There is a possibility, but only on the level of
separately from the salary and if yes, what kind
federal countries (Bundesländer).
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Table 4 Result for Germany
9
Conclusion
Since 2009, the “holiday pay” since 2009 has been integrated in the monthly salary, but this is only
the law for public servants. For civil servants on local level it can be either integrated in the regular
salary as for the public servants or it can be paid once a year, in most cases at the end of November
or beginning of December.
10
Ireland The current population of Ireland is 4.82million, based on the latest United Nations
estimates (Worldometers 2019).
More than 300,000 public servants work across a broad range of public organisations to deliver
public services to the people of Ireland. This includes working in areas of education, defence,
conservation, economics, health or public policy.
There are 17 Government Departments including bodies such as the Garda Síochána, that works
under the Department of Justice and Equality, and the Irish Health Service Executive, that works
under the Department of Health. These Departments and Agencies work together to implement
policies and services for the Irish people. The following table shows the figures about the public
sector in Ireland (Gouvernment of Ireland 2018).
Table 5 Public Sector in Ireland
The Act provides for a basic annual paid leave entitlement of 4 weeks, although an
employee's contract could give more benefits.
It is for the employer to decide when annual leave can be taken, but this is subject to a number of conditions. The employer must take into account family responsibilities, opportunities for rest and recreation that are available at least one month before the leave is to be taken. In addition, annual leave should be taken within the appropriate leave year or with the consent, within 6 months of the relevant leave year. Payment is done in respect of annual leave in advance at the normal weekly rate. There is no extra pay for holidays (Annual leave citizens 2019).
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Results for Ireland
Is “holiday pay ” in your country accounted
separately from the salary and if yes, what kind
No, there is no extra payment for holidays
of legal act oblige that?
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
No, there is no extra payment for holidays
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Table 6 Result for Ireland
Conclusion
There is no extra pay for holidays in Ireland neither for the private nor for the public sector.
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Italy The current population of Italy is 59.251, based on the latest United Nations
estimates (Worldometers 2019).
Around 15.4% of the population is employed in the public sectoron the state level as well as on the
country level. At the local level act numerous units grouped according to a criteria similar to that of
the Central governments. There are 20 regions and the 2 autonomous provinces which competencies
are similar to that of the state at the local level, also if they are mainly focused on the coordination
of the other bodies that operate in their areas, instead of being engaged in the production of
services, at a local level act Provinces and Municipalities that are mainly involved in the production of
services, redistribution activities and in the formation of fixed capital, too. (OECD, National Accounts
and Economic Statistik 2017).
Employees are entitled to be paid for the national bank holidays as well as certain local municipal
bank holidays. They are also entitled to a minimum of 22 days of vacation (prorated new hires)
and 88 hours of permissions as from the 5th year of employment (1st & 2nd year 32 hours, 3rd &
4th year 60 hours), while managers (dirigenti) are entitled to 30 days of vacation (prorated new
hires) and 32 hours of permissions per year for a full time employment (2019 ITALY BENEFITS
SUMMARY 2019)
If holidays are not used before the termination of employment, the employee will receive an
indemnity in lieu of vacation calculated on the basis of salary at the time of payment. In the
absence of a legislative framework specifying the elements of the remuneration which must be
taken into account, Italian Case Law states that the holiday indemnity should be determined by
collective bargaining or by individual agreement, and confirms that – in any case – it must ensure
that the employee's pay is the same as the employee would have received if working (Supreme
Court Decision 5408 of 2003) (Lovells 2014).
Subordinate employees are persons who, in consideration of a certain salary, bind themselves to
perform their intellectual or manual work activity within the public, under the management and the
control of their employer (Article 2094, Italian Civil Code). These are self-employed workers paid to
undertake to continuously promote the conclusion of a series of contracts in a certain area on behalf
of the principal. All employees are entitled to a minimum of four weeks' paid annual holiday.
Collective bargaining agreements (CBAs) and individual contracts can provide for a longer period of
holiday entitlement. Annual leave cannot be replaced by a payment in lieu, except where the
employment contract is terminated. There is no extra pay for holidays (Thomson Reuters 2018).
Result for Italy
Is “holiday pay” in your country accounted
separately from the salary and if yes, what kind
No, there is no extra payment for holidays
of legal act oblige that?
Is ”holiday pay” in your country paid in advance No, there is no extra payment for holidays
of holiday (or if such a possibility exists)
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separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Table 7 Result for of Italy
Conclusion
All employees are entitled to a minimum of four weeks' paid annual holiday. There is no extra pay
for holidays in Italy neither for the private nor for the public sector.
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Luxemburg Luxembourg's population counts about 602,005 residents. Among them, 313,042 are Luxembourgers
and 288,963 have a foreign nationality — they represent 48% of the entire population. In the capital,
this percentage exceeds 69%. Also due to the ECB being situated there.
Public employment represents 12% of the overall labour market in Luxembourg which is a slight
raisefrom 11% in 2000. According to a Statec report on "permanent employment in the public
sector", Luxembourg had 40,007 public employees in 2017. Among EU Member States, only Germany
has a lower proportion, topping the Eurostat ranking with 10% (Le Gouvernement du Grand Duche
de Luxembourg 2018).
Luxembourg is one of the top European countries for paid vacation days. The legal duration of annual
leave is set to a minimum of 25 working days per year. In comparison, the majority of workers in
Belgium, France and Germany are entitled to at least 20, 25 and 24 working days’ leave per year.
Moreover, a collective or an individual agreement between the employer and the employee may
include additional days of leave for the employee (Jess 2019).
The officials in Luxembourg received their 13th salary («Allocation de fin d'année») in December.
Employers in the private sector in principal are not obliged to pay a 13th salary or Christmas
bonus, unless it is stated in the employment contract, collective contract or in the company
agreement (Tschürz 2018).
The official gets a „end of year“-extra pay together with the December salary according to art. 22,
CONTRAT COLLECTIF DES OUVRIERS DE L’ETAT. This bonus is paid automatically together with the
December salary and can be viewed as Christmas and holiday payment.
Result for Luxemburg Is “holiday pay” in your country accounted separately from the salary and if yes, what kind of legal act oblige that?
No
Is ”holiday pay” in your country paid in advance of holiday (or if such a possibility exists) separately from the salary and if yes, what kind of legal act oblige that; If there is just a possibility, please describe the conditions, on which such possibility could be implemented.
No
Table 8 Result for Luxemburg
Conclusion
There is a special payment for officials in the public sector for holidays at the end of each year paid
together with the salary of December. This payment is not paid separately from the salary.
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Slovenia The Republic of Slovenia has a population of approximately 2’070’050 million inhabitants (Republic
of Slovenia Statistical office 2018), and about 22.9% of them are employed in the public sector. Full
working time is fixed on a weekly basis and usually amounts to 40 hours a week. It can be less but
not under 36 hours a week. Where there is a great risk of injury or harm to health, full working time
may be under 36 hours a week. Full working time may not be spread over less than four days a week.
(Republic of Slovenia Statistical office 2018).
Discussions among social partners in Slovenia in 2017 covered different areas of working life. Top of
the policy agenda were wage negotiations in the public sector, but social partners and the
government also agreed on and implemented important reform measures in the areas of labour and
family policy. The minimum wage is calculated in accordance with the Minimum Wage Act adopted
on 11 February 2010 on the basis of published data on inflation. The Act stipulates that the
minimum wage be adjusted annually in line with the rise in consumer prices. The official data from
the Statistical Office of the Republic of Slovenia (SORS) on the annual rise in consumer prices for the
previous December-to-December period is used to calculate minimum wage adjustments. The
following table shows the statutory of the minimum wage 2013-2017 (Eurofund EU Commission
2017).
Table 9 Minimum wage 2013-2017
In the Republic of Slovenia it is stated in the Labour law that a special payment for holidays, which
says that the employer, has to be paid to the employees (at least the minimum wage) at the latest
1th of July (Republic of Slovenia Law information system PIS 2018).
In this case it refers also to public servants, because there is no other legal document saying anything
different. The government and the syndicate brought together a collective agreement for the public
sector, where the special payment for holidays was defined as holiday money (REPUBLIKA SLOVENIJA
MINISTRSTVO ZA JAVNO UPRAVO 2018).
But for the year 2017 and 2018 there was no document to declare an amount of money as holiday
money, which means that the officials according to the Labour law receive at least the minimum
wage as holiday money.
Result for Slovenia Is “holiday pay” in your country accounted separately from the salary and if yes, what kind of legal act oblige that?
Yes, mainly Labour law, or collective agreement
Is ”holiday pay” in your country paid in advance of holiday (or if such a
possibility exists) separately from the salary and if yes, what kind of
legal act oblige that; If there is just a possibility, please describe the
conditions, on which such possibility could be implemented.
Yes, it must be paid until
1st of July because it is for
summer vacation
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Conclusion
In the Republic of Slovenia in the Labour Law it is declared that all employees have the right to get
holiday money before the 1st of July and it can’t be less than the minimum wage for the running
year. If the public sector is part of the collective agreement which says that there is specific amount
of money then the officials get holiday money. But this kind of regulation through the collective
agreement must be renewed every two years or if not, the Labour law acts as regulator. This
happened for the year 2018 and all officials got just the minimal wage for their vacation.
Czech Republic The current population of Czech Republic is 10,62 million, based on the latest United Nations estimates (Worldometers 2019).
The Ministry of the Interior is, besides other, responsible for the public administration and management of public employees. However, in practice, staff management is decentralised. Although the State is formally the only employer, there is currently no independent central management, so each ministry or other state body acts de facto as an independent employer, with the power to recruit, promote and dismiss its employees based on the Labour Code and on the internal working rules of each administrative authority. There are 680 000 public employees, representing 6.6 % of the total population. 17 486 employees work in the central administration bodies (EU 2016). The percentage of the public sector employment is listed In the following table (OECD 2014).
Figure 1 public sector employment Czech Republic
Public employees in the Czech Republic are regulated by the same regulation as the private sector, i.e. the Labour Code (Nr. 262/2006 Coll.).
Status of Civil Servants:
Civil servants in central administration: Their status is regulated by the 2006 Labour Code (262/2006 Coll.) until the Civil Servants Act passed in 2002 (218/2002 Coll.) comes into force or is replaced by a common legal norm for both types of officials (i.e. civil servants in central public administration as well as in territorial self-governing units).
Civil servants of the territorial self-governing units(municipalities and regions): Their status is regulated by Law (312/2002 Coll.) on civil servants in territorial self-governing units, which stipulates employment conditions and the qualifications required for local government employees.
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The rights and duties of all public employees are set out in the Labour Code and there are no differences with the private sector. However, civil servants have additional obligations such as abiding by the law, striving to serve public interest, remaining impartial, and observing hierarchical obedience
(EU 2016).
The normal full statutory annual leave entitlement is four weeks in the private sector and five weeks in the public sector. Teachers and academic university staff are entitled to eight weeks of annual leave, During annual leave, employees are not entitled to wages, as such. Instead they receive "holiday compensation" equal to their average earnings for the period of leave (Legislation 2019). Furthermore there is no other type of payment for the holiday money in the Czech Republic.
Results for Czech Republic Is “holiday pay” in your country paid separately
from the salary and if yes, what kind of legal act
oblige that?
No
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
No
Table 1 Result for Czech Republic
Conclusion
There is no extra pay for holidays in in Czech Republic neither for the private nor for the public sector.
ESTONIA The current population of Estonia is 1,30 million, based on the latest United Nations estimates
(Worldometers 2019).
As of 31 December 2015 in total, 29 384 public servants were employed in public service in Estonia, including 23 920 public servants were employed in state administrative agencies and 5 464 public servants in local government administrative agencies. Majority of the public servants (22 478) are employed in inspectorates and administrative agencies implementing public policies. The biggest of the state administrative agencies are Police Board (4 132 officials) and Tax and Customs Board (1 941). Estonian ministries, which have mainly a policy-making role, are relatively small, employing all together only 2 889 people. Concerning other factors, the Estonian public servants are relatively young (55 % are under the age of 40 and 25 % are under the age of 30); women prevail in all groups of public servants (54.6 %); the proportion of officials with degree in higher education is remarkable (55 % of public servants and 92.7 % of senior positions are university graduates). The Public Service Code of Ethics, which was included as an Annex to the Public Service Act in 1999, prescribes 20 principles and values that all public servants are expected to hold (for example: performing their functions impartially. based on respect for the Constitution and other laws, pursuing
18
the public interest etc). According to the Anti-Corruption Act, the officials are obliged to submit annually declarations of their economic interests. In addition the public officials do not have the right to strike. Rights of public servants include Pregnancy Leave and Maternity Leave 140 days (European Commission 2018).
The vacation pay is paid out on the second-to-last workday before the beginning of the vacation. The parties may agree that the vacation pay will be paid later, but not later than on the first salary day after the end of the vacation. Unused vacation days are monetarily compensated for only when the contract of employment is terminated. The vacation pay is calculated based on the six months’ remuneration received by the employee prior to the vacation. The salary and calendar days of the six months are summed up. Public holidays and the days when the employee was absent for a significant reason (e.g. illness, vacation, military service, or representation of employees based on conditions stipulated in the collective agreement) are not included in this calculation. The remuneration sum is divided by the number of calendar days, which gives the average calendar day salary. The result is multiplied by the number of calendar days of the length of the vacation. This gives us the vacation pay size (TÖÖELU 2017). According to the Civil Servis Act Chapter 3 §43 the length of the basic holiday of an official is 35 calendar days.
Results for Estonia Is “holiday pay” in your country paid separately
from the salary and if yes, what kind of legal act
oblige that?
No
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
No
Table 2 Result for Estonia
Conclusion
There is no extra pay for holidays in Estonia neither for the private nor for the public sector.
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FINLAND The current population of Finland is 5,50 million, based on the latest United Nations estimates
(Worldometers 2019).
The Personnel and Governance Policy Department of the Ministry of Finance acts as the Office for the Government as Employer (VTML). The Office for the Government as Employer represents the Government as an employer in the centralised collective agreement negotiations for the whole labour market as well as their preparation, makes the collective agreements for public servants and other employees on the central government level, and supports and steers the activities of agencies regarding agreements as well as other activities as employer. The Office for the Government as Employer prepares the state's personnel management policy definitions on a strategic level and ensures that they are implemented. The activities of the Government as an employer include preparing legislation related to state personnel, estimating the personnel costs in the Budget and developing the information management in personnel management and the activities as an employer. The employer field covers the agencies within the Budget, which employ approximately 73,000 people (Ministry of Finance 2019). The following figure shows the total employment in the government in Finland (OECD 2017).
Figure 2 public sector employment Finland
The amount that is awarded for the Holiday pay depends on salary level and how long a person has worked, but it is normally 50 % of the normal pay. Holiday bonuses will be paid with the wage payment for July in national government service and in certain private sectors, and with the wage payment for August in local government service (Suomi 2019). Public sector workers are facing a 30 % cut to their holiday bonus from summer 2017, the first in a series of three. The pact's temporary cut to holiday bonuses will affect over 500,000 municipal and state employees between the years 2017 and 2019. The holiday bonus cuts that are currently on the table will affect 429, 000 municipal workers and 72,000 state employees (uutiset 2019).
Results for Finland Is “holiday pay” in your country paid separately
from the salary and if yes, what kind of legal act
No
20
oblige that?
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Yes , with payment for July
Annual Holidays Act 162/2005 Chapter 3
Table 3 Result for Finland
Conclusion
There is holiday money for the public sector that is normally 50% of the average salary, but 2017-2019 there is a cut of 30%. Holiday money is paid in advance of the holiday together with the monthly salary.
POLAND The current population of Poland is 38,05 million, based on the latest United Nations estimates
(Worldometers 2019).
The Polish public administration employs approximately 643 000 staff, not including teachers, doctors, soldiers or officers. Of this number, about 122 000 (about 19%) are members of the civil service corps. Employment in general government as a percentage of the total labour force in Poland was 9.7%, well below the OECD average of 15.0%. The government of Poland’s civil service system is governed by the Civil Service Act (2008) and is generally competitive and open, according to the Supreme Audit Office – i.e. the process is universal, transparent and conducted in accordance with the principle of equality. The system is hybrid; exhibiting elements of both a career-based and position-based model, with a tendency toward the position-based model (OECD 2017). The following figure shows the average employment by administrations (Chancellary of the Prime Minister 2019).
Figure 2 employment by Administrations
21
The public administration is obliged to pay out a Christmas bonus to anyone who worked for a minimum of 6 months in the given calendar year amounting to 8,5% of the total earnings as mentioned in Dz. U. Nr 160, poz. 1080 z późn. Zm (Radio Polski 2014). There is no holiday pay in Poland.
Results for Poland Is “holiday pay” in your country paid separately
from the salary and if yes, what kind of legal act
oblige that?
No
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
No
Table 4 Result for Poland
Conclusion
There is no extra pay for holidays in Poland neither for the private nor for the public sector, only a Christmas bonus for the employees in the public sector.
22
UNITED KINGDOM The current population of UK is 66,82 million, based on the latest United Nations estimates
(Worldometers 2019).
Of the 5.36 million people with public sector jobs, 1.64 million work in the NHS and 1.5 million
in education. The NHS employs 30.6% of all UK public sector staff, with education not far
behind, employing a further 28% of public sector staff. Some 1.03 million people work in public
administration, in both central and local government, well down on the 2005 peak of 1.29
million. The figure includes the civil service, which employs 430,000 people. For the first time
since 2009, there was an underlying increase in 2017-18 in public sector employment as a
whole across the UK, but more than 1.1 million jobs have been lost in the public sector since
its peak of 6.46m in September 2009.
Figure 3 public sector employment
The UK private sector employs 27.04 million people. The public sector now accounts for
16.5% of UK employment, the lowest percentage since records began in 1999 (Guardian
2019).
There is also a Privilege day in addition to annual leave granted to employees of the civil
service, which is the Queen`s official birthday. Bonuses in the public sector are paid only for
delivering of personal in-year business objectives. There is no extra Holiday pay for civil
servants in the UK (Stanly 2018).
Results for United Kingdom Is “holiday pay” in your country paid separately
from the salary and if yes, what kind of legal act
oblige that?
No
Is ”holiday pay” in your country paid in advance
of holiday (or if such a possibility exists)
separately from the salary and if yes, what kind
No
23
of legal act oblige that; If there is just a
possibility, please describe the conditions, on
which such possibility could be implemented.
Table 5 Result for United Kingdom
Conclusion
There is no extra pay for holidays in United Kingdom neither for the private nor for the public sector.
24
Summary of Results Austria “holiday pay” is not accounted separately from
the salary and not paid in advance of holiday
separately from the salary.
Czech Republic No holiday pay
Croatia “holiday pay” is accounted separately from the
salary and it must be paid at least 15th of July
Estonia No holiday pay
Finland “holiday pay” is not accounted separately from the salary
Germany “holiday pay” is not accounted separately from
the salary and not paid in advance of holiday
separately from the salary.
Ireland No holiday pay
Italy No holiday pay
Luxembourg “holiday pay” is not accounted separately from
the salary
Poland No holiday pay
Slovenia “holiday pay” is accounted separately from the
salary and it must be paid till 1st of July
United Kingdom No holiday pay
Table 6 Summary of Results
Comparison of the Results
Eastern European member states are: Croatia, Czech Republic, Estonia, Poland, Slovenia
Western European member states: Austria, Finland, Germany, Ireland, Italy, Luxemburg and UK
The first statistics is between Eastern and Western Europe EU-member states and shows the
percentage of holiday payment in the countries.
The 2nd statistics shows the percentage of countries there is an automatically payment of holiday
money and in where it is paid separately from the salary.
The 3rd statistics shows that in all Western European member states the holiday money is paid
automatically together with the monthly salary whereas in the Eastern EU member states it is paid in
advance of the holiday, separately from the monthly salary.
Conclusion
Over the past two decades, Lithuania has made significant progress towards a more efficient public
administration. Many endeavours have been made to increase civic awareness and to encourage
citizens’ participation in public governance. Today, the Lithuanian Authorities seek to support the
government’s efforts to promote open and inclusive policy-making and implementation, as well as to
improve the government-institutional framework as well as the relations between the government
and the civil society. The accounting and payment system is a main application of the Shared Service
Centre in Lithuania. Public employees get their holiday pay in advance of their holiday, if they do not
express to get it money together with the next salary.
Because of this regulation it is complicated to get the most efficient and effective IT System in place.
In comparison to other European countries there is no such possibility that the employee can decide
about the way or time of payments of holiday pay.
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