Topic: How many paid leave days, how overtime is paid — what differs across seven countries
What does Brazil require?
Everyday topic
Brazil's consolidated labor code, the CLT, grants 30 days of annual leave under Article 130, contingent on completing a 12-month "acquisitive period" — but unjustified absences during that year cut the total down: 24 days if there were 6 to 14 absences, 18 days for 15 to 23, and just 12 days for 24 to 32 — the more absences, the less leave, a design unique to Brazil that ties vacation length directly to attendance. Leave must be scheduled within 12 months of becoming eligible (the "concessive period"), and if the employer misses that deadline, the law requires paying for that leave in double (Arts. 134 and 137). Workers can also convert up to a third of their leave into cash, but must request it at least 15 days before the acquisitive period ends (Art. 143). On overtime, the minimum premium is written directly into the Constitution — Article 7(XVI) sets it at least 50% above the normal wage — and CLT Article 59 adds a hard ceiling of 2 extra hours a day: however much you want the overtime pay, the day itself caps out at two hours of it.
What is this topic?
Taiwan's Labor Standards Act Article 38 tiers annual leave into six bands: 3 days at six months, 7 at one year, 10 at two years, 14 a year from three to five years, 15 a year from five to ten years, and one extra day per year after ten, capped at 30 — and unused days aren't lost, since Article 38(4) requires the employer to pay wages for them.
Japan's Article 39 starts at 10 days after six months and rises to a 20-day cap at 6.5 years; since 2019 employers must ensure workers with enough entitlement actually take at least 5 days, but under Article 115 anything left unused after two years simply expires — no payout.
Mainland China's Regulation on Paid Annual Leave requires 12 months of continuous service to qualify, then grants 5, 10, or 15 days by cumulative tenure, with 300% of the daily wage owed for any day the employer fails to schedule (Art. 5).
US federal law has no statutory annual leave at all — the Fair Labor Standards Act simply doesn't regulate vacation, leaving whether and how much to employers or states.
India's leave protection long lived only in Factories Act Section 79, covering factory workers who hit 240 days a year at one day per 20 worked; shops and services were always governed by separate, inconsistent state laws, and a national labour code only lowered the threshold to 180 days in November 2025.
Indonesia's Manpower Law Article 79 grants 12 days after 12 months; the old mandatory two-month long-leave benefit after six years' service is now merely optional under the amended law.
Brazil's CLT Article 130 grants 30 days, but unjustified absences during the year shrink it, and a worker may cash out up to a third of it (Art. 143).
Overtime pay diverges even more: Taiwan pays a one-third premium for the first two extra hours and two-thirds beyond that; Japan adds a 50% premium past 60 hours a month; China runs three tiers — 150% on weekdays, 200% on rest days, 300% cash-only on statutory holidays; the US only counts 1.5x for hours past 40 in a week, with no daily rule and no hour cap; India pays a flat double time beyond statutory hours; Indonesia pays 1.5x the first hour and 2x after, capped at 4 hours a day; Brazil requires at least a 50% premium but caps overtime at 2 hours a day.
Sources and dates
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