Maternity Leave – How Different Countries Treat Working Mothers?

How a society treats working mothers, tells much about that society and its values. Is that really true? 

Why doesn't rich USA pay maternity leaves to its mothers? 

• There are only 2 poor countries in the world, Papua New Guinea and Swaziland that probably cannot afford to pay. 
• Even the United Nations pays its women employees 16 weeks at 100% salary maternity leave.

Photo Source: Wikimedia Commons

Ask any mother and she will tell you that in addition to the material needs of the mother and her baby (e.g., the ability to pay all bills), a mother needs practical help and guidance, support with social and emotional reassurance, physical comfort and health, and appreciation.



What is Maternity Leave?

Maternity leave, often called parental or family leave, is the time a mother (or father to some degree) takes off from work for the birth or adoption of a child. 

State paid "maternity leave" —the norm in most Western and some other countries, developed or even developing — is absent in the United States. 

Some enlightened US companies do offer new parents paid time off, up to six weeks in some cases.



Why Should the State Pay Maternity Leaves?

The idea that the state should be responsible for providing money to help maintain mothers who have given birth, and cannot work as usual is absent in most ancient societies. The responsibility for maintaining mothers and children was the husband’s, families or the community’s. 


Even the largest matrilineal society in the world today, the Minangkabau of West Sumatra, in Indonesia does not have this concept. In the Minangkabau culture, property and land passes down from mother to daughter, while business, religious, and political affairs are the province of men (although some women do play important roles in these areas). Very prescient these Minangkabau! They knew long before the current financial crisis that businesses fail, religions get corrupted not to talk about politics, but property and land retain value.

Photo Source: Wikimedia Commons 

Never before have so many mothers needed to work outside the home along with men (excluding the farm). In an increasing numbers of societies one income is not enough to support a family.

The custom of paid maternity leaves varies greatly among countries. 

• Cuba already started paying maternity leaves to working mothers in 1934 
• Sweden in 1931. 
• Afghanistan and Iran have 90 days maternity leave paid by the state. 
• The tiny Estonian government gives a generous 455 calendar days with 100% salary compensation to mothers
• The rich and mighty United States government has no national provision for paid maternity leave.
• Only 2 US states, California and New Jersey pay six weeks of maternity leaves though the jobs are not guaranteed

A diminishing number of children endanger the continuity of the nation state. In Estonia, protecting and nurturing each child, and the more the better is a prime directive for preserving the ethnic Estonian nation. In 1761, British physician William Buchan (1729–1805) noted that one half of the human race dies in infancy, with ominous consequences for the health of the state. 

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Deborah Dwork (1987) in her book “War Is Good for Babies and Other Young Children: A History of the Infant and Child Welfare Movement in England 1898-1918 “ claims that WWI, was actually good for motherhood and childbirth in Britain.

Women Working Till Delivery Day Have More Cesarean Sections Women who worked right up to the delivery day were more likely to have a costly cesarean section, according a study funded by the U.S. Health Resources and Services Administration. 

A second study found that the longer a new mother delayed returning to work, the more likely she was to breastfeed – a practice recommended by other studies and the American Academy of Pediatrics to decrease the risk of allergies, obesity and sudden infant death syndrome.

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History of Paid Maternity Leaves in Different Countries

Paid maternity leaves were first established, in a modern context, as a part of social insurance by Bismarck in Germany in 1883. France followed soon. In 1919 the International Labor Organization, adopted its first convention claiming that mothers be entitled to a maternity leave of 12 weeks in two equal parts preceding and following childbirth. 


In most western countries parental leave is available for those who have worked for their current employer for a certain period of time. Sweden provides generous parental leave: all working parents are entitled to 16 months paid leave per child, the cost being shared between employer and State. 

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Other Opinions on Maternity Leaves

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The extension of maternity leave to up to a year may be sabotaging women's careers according to Nicola Brewer, chief executive of the Equalities and Human Rights Commission in UK. She claims that some employers were thinking twice about offering women jobs or promotion.



First Israeli Gay Man Gets 'Maternity' Leave

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The National Insurance Institute authorized Israel's first-ever "maternity" leave for a male couple on Thursday. 

Yonatan Gher, director of Jerusalem's nonprofit Open House Pride and Tolerance organization, has received institute approval of a 64-day leave from work on the occasion of the birth of his biological son, born of a surrogate mother in India.

How is Citizenship for Babies Born on Airplanes Decided?

How is the citizenship of babies born mid-flight decided? 

Is it according to: 

• the parents' citizenship
• the territory/airspace over which the birth takes place in mid-air
• the nationality of the airline or where it is registered
• the destination of the flight
• the port of departure of the flight

Last week a Swedish pregnant woman, flying by Finnair from Bangkok to Helsinki gave birth to a baby over Kazakhstan.

Photo Credit: Aneta Blaszczyk


This has happened before on other airlines, but was a first for the Finnish airline. There were even two doctors and two nurses on board, among the passengers. She was in good hands and everything went really well for the mother and the baby.

Does the baby get Swedish citizenship, according to the mother, Kazakhstani citizenship because she arrived over Kazakhstani airspace, Thai citizenship according to the port of departure, Finnish citizenship according to the destination and because the airline was Finnish (mostly state owned airline)?

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Two Methods of Deciding Citizenship of Babies

There are basically two systems of deciding citizenship: jus solis or according to birthplace and jus sanguine, according to ethnicity, race, i.e., according to blood factors. Some countries also apply either principle but in a muted manner to suit political and social exigencies. 

India, for instance applies the mixed principle of jus sanguine and jus solis, but adjusts it to mean that children born on Indian soil on or after 3^rd December, 2004 is considered citizen of India by birth if both the parents are citizens of India or one of the parents is a citizen of India and the other is not an illegal migrant at the time of the child's birth.

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Countries with low birth rates who plan to increase their population bases usually apply the principle of jus solis to integrate everyone who was born in their territory. Sweden, like Finland thus applies the principles of jus solis. But many countries like the USA, Canada, Germany and Ireland have a practice of mixing jus sanguinis and jus soli. The United States grants citizenship to babies born in their airspace, even if the mother happens to be a Mexican citizen as in this case.

What would happen if the baby were born over international territory, above the seas? Would she then be a stateless person or a world citizen?

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Airlines are rather strict about requiring medical certificates for pregnant mothers beyond their 28th week of pregnancy. These are more relaxed for short domestic flights and even for flights within the Nordic countries. These mid-air childbirths are not happening in the hundreds every day. So, authorities deal with them on a case-by-case basis. Further, there is an international agreement called the UNHCR 1961 Convention on the Reduction of Statelessness. Finland ratified this agreement on 7^th August 2008 and Sweden in 1969. Kazakhstan has not signed this agreement, so the baby cannot be given Kazakhstani citizenship.

Considering the above, Kazakhstani citizenship is out of the question, unless the parents apply for it and the Kazakhstani government snatches a great PR opportunity and grants it. 

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Finnish citizenship is also possible, especially if the parents are permanently resident in Finland. What is left is the most logical and natural alternative – the baby is a Swedish citizen.

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Let us warmly welcome her to the world and wish her a good and happy life with lots of flying miles and frequent flyer rewards (whatever her citizenship turns out to be).