Topic: How many paid leave days, how overtime is paid — what differs across seven countries
What does India require?
Everyday topic
For decades, India's annual leave rule lived only in Section 79 of the Factories Act, 1948, and it covered only factory workers: anyone who worked at least 240 days in a calendar year earned one day of leave for every 20 days worked (adults) or every 15 days (child workers), with carryover capped at 30 days for adults and 40 for children. What matters more is what it never covered — shops, restaurants, offices, and other commercial establishments, which fell instead under separate state-level Shops and Establishments Acts, each state writing its own rules. India has, in effect, never had one uniform national annual-leave standard. That changed on 21 November 2025, when four new labour codes came into force nationwide; the Occupational Safety, Health and Working Conditions Code folded thirteen laws — including the Factories Act — into one, and lowered the qualifying threshold from 240 days to 180 days, while keeping the same one-day-per-20-days conversion. Overtime pay is comparatively blunt: under the old rule, working beyond 9 hours a day or 48 hours a week triggered double wages; the new code changed the daily trigger to 8 hours (weekly stays at 48), but the multiplier is unchanged — still double.
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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