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Topic: How many paid leave days, how overtime is paid — what differs across seven countries

What does Indonesia require?

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Indonesia's Manpower Law, Article 79, entitles a worker to 12 working days of annual leave after 12 months of continuous employment with the same employer, with the details of how it's scheduled left to the employment agreement, company regulations, or a collective agreement (Art. 79(3)-(4)). What's really worth comparing is what got taken away: the old law used to mandate a full two-month "long leave" in years seven and eight for anyone with six years of continuous service — a hard requirement. After the 2023 omnibus Job Creation Law amendment, the text now says "certain companies may provide long leave" — shifting from a mandate to something that only exists if a company or collective agreement chooses to grant it. Overtime rules were also rewritten in Government Regulation No. 35 of 2021: a cap of 4 hours a day and 18 hours a week (Art. 26), with pay at 1.5 times the hourly wage for the first hour and 2 times for every hour after that (Art. 31) — a generous first-hour rate, but the 4-hour daily ceiling is a hard limit, unlike Taiwan or Japan where negotiation can push it higher.

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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.

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