Topic: How many paid leave days, how overtime is paid — what differs across seven countries
What does United States require?
Everyday topic
US federal law imposes no requirement at all that employers provide paid vacation — and that absence is itself the sharpest outlier among the seven countries. The Department of Labor states it plainly: the Fair Labor Standards Act does not require payment for time not worked, whether vacation, sick leave, or federal holidays — those are matters left entirely to agreement between employer and employee (or a union), with no federal floor. The one carve-out is federal contractors covered by the McNamara-O'Hara Service Contract Act or the Davis-Bacon Act, who may be required to provide vacation as a fringe benefit. Overtime, by contrast, is a clean single rule: non-exempt employees must be paid at least 1.5 times their regular rate for any hours worked beyond 40 in a single workweek (29 U.S.C. § 207), with no federal daily-overtime trigger and no averaging hours across different weeks to cancel it out. Just as notable: federal law places no limit at all on how many hours a worker aged 16 or older can be required to work in a week — as long as the overtime premium gets paid, there is no statutory ceiling on the hours themselves.
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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