Paternity rights differ drastically around the world. With Father’s Day just around the corner, we are looking at parental leave and what happens when parents split up in six countries popular with overseas property buyers.
As gender equality becomes the norm and women achieve parity in the workplace, many men are seeking a level playing field in the home too. We all expect gender equality these days, but some countries are more equal than others.
We all expect gender equality these days, but some countries are more equal than others.
Like in the UK, Australian dads get two weeks paid paternity leave to help care for a new-born infant. At a more political level, since the 1970s fathers’ rights organisations have grown up in Australia, advocating the cohesion of the family unit, equal custody and child access in the event of family breakdown. The Men’s Rights Agency, for example, works to improve the balance between men and women and provide a better atmosphere in which to raise children. In 2006 Australia implemented the Family Law Amendment (Shared Parental Responsibility) Act. This act is centred on the concept of equal shared parental responsibility, and promotes the shared responsibility of decision-making for the benefit of a child.
A newly introduced 18-month parental leave scheme allows mothers or fathers to take 35 weeks of parental leave after the birth of a new child. In Canada fathers are entitled to paternity rights and child custody, and it is the court’s decision who the primary carer is in the case of a separation. There are a handful of organisations in Canada that advocate rights for men, such as Dads Canada, a Toronto based non-profit father’s support group.
Men are permitted to take 11 days off work following the birth of a new child, while women in France are eligible for 16 weeks paid leave. Parental authority in France after separation continues jointly unless it is in the best interest of the child to award primary care to one parent over another. There are a total of 117 national and regional organisations which promote parental equality after separation with respect to child custody in France: including SOS PAPA, SVP Papa and LPLM.
In 2016 men in Spain were granted the same parental leave rights as women following the birth of a new baby, with the period extended from just 13 days to a whole 16 weeks. Joint custody is the preferred model of parenting when a family dissolves in Spain, but as recently as 2009, 84% of children were in sole custody of the mother, 5.6% with the father and 9.6% in joint custody.
When planning to move to France, Spain, Portugal or Italy, you’ll have a thousand detailed questions. At Your Overseas Home, a new style of property and advice show, you will have all the time you need to get answers. Saturday, 24th June, Manchester. Further details here.
In terms of paid paternity leave Sweden has one of the most equal systems in the world. It is not uncommon for Swedish men to take six months off work to care for a new born child, and then have a gradual return to work schedule. This generous parental scheme was introduced way back in 1974. In Sweden the majority of child custody cases are awarded to the mother if joint custody is manifestly incompatible. There are several paternity rights groups in Sweden that fight for father’s rights in the court, the largest being Min Pappa.
Today in America not all dads have rights to paternity leave after the birth of a child. Currently only 12% of non-government workers in the USA have access to paid parental leave (men and women). Women are entitled to 12 weeks job protected unpaid leave, while men have no entitlements. There are a number of father’s rights movements in the USA advocating for gender equality, antidiscrimination with alimony and the end of presumptive maternal custody – the American Coalition for Fathers and Children (ACFC) is a particularly prominent one.
Paternity rights around the world are varied, with some countries still favouring the rights of women when it comes to parenting. If you are a father or a father-to-be and are thinking of relocating to another country, understanding the paternity rights in your new destination is important. For more information about living and buying property abroad make sure to check the Property Guides; everything you need to know what life is like as a UK expat or retiree living in another country.