The point.
- The employer stage is the variable most comparisons leave out, and it runs from up to 104 weeks at 70% of pay in the Netherlands to 28 weeks in Britain, 6 weeks in Germany, 30 working days in Slovenia inside an annual cap of 80 working days, and none at all in Portugal.
- Britain has no state stage, so the employer pays all 28 weeks at the lower of £123.25 a week or 80% of normal weekly earnings, while Germany's 78 weeks of Krankengeld include the six employer weeks.
- France runs the other way round, with the state paying from day 4 and the employer top-up starting at day 8, so the first three days are paid by nobody. With a year's service the employer has to bring the combined total to 90% of gross, and the state benefit is deducted from what it owes rather than added to it.
- The ceiling decides what lands in the account, not the percentage. France caps the state benefit at €42.97 gross a day, so 50% of a €3,500 monthly salary works out at 37%.
- Four of the nine give a self-employed person nothing: Britain and Ireland by rule, the Netherlands in practice, and Italy mostly, apart from Gestione Separata.
The point.
- The employer stage is the variable most comparisons leave out, and it runs from up to 104 weeks at 70% of pay in the Netherlands to 28 weeks in Britain, 6 weeks in Germany, 30 working days in Slovenia inside an annual cap of 80 working days, and none at all in Portugal.
- Britain has no state stage, so the employer pays all 28 weeks at the lower of £123.25 a week or 80% of normal weekly earnings, while Germany's 78 weeks of Krankengeld include the six employer weeks.
- France runs the other way round, with the state paying from day 4 and the employer top-up starting at day 8, so the first three days are paid by nobody. With a year's service the employer has to bring the combined total to 90% of gross, and the state benefit is deducted from what it owes rather than added to it.
- The ceiling decides what lands in the account, not the percentage. France caps the state benefit at €42.97 gross a day, so 50% of a €3,500 monthly salary works out at 37%.
- Four of the nine give a self-employed person nothing: Britain and Ireland by rule, the Netherlands in practice, and Italy mostly, apart from Gestione Separata.
Two years. That is how long a Dutch employer has to keep paying a sick employee at 70% of their wage before the state comes into it at all. A Portuguese worker in the same position gets nothing from an employer at any point, and nothing from anyone for the first three days.
Either you are ill now, or you have started doing the arithmetic on what happens if you are. Both are fair. Sick pay in Europe isn’t one system with nine local accents. It is nine systems, and the number that decides how bad your next month gets is not the percentage everybody quotes.
The nine are the Netherlands, Britain, Germany, Slovenia, France, Spain, Ireland, Italy and Portugal. If you live elsewhere in Europe your scheme is not one of these, and the European Commission’s MISSOC comparative tables (opens in new tab) carry the rest, as at January 2026. Everything up to the last table assumes you are an employee. Four of the nine give a self-employed person nothing at all, and that section is at the bottom.
Who pays you for the first month?
An employer in six of the nine, the state first in France, and never an employer in Portugal; whether Italy’s first three days are paid at all depends on your collective agreement.
| Market | Waiting days (and who pays them) | Employer-paid stage | State stage starts |
|---|---|---|---|
| Netherlands | 0, or up to 2 if your contract or collective agreement, the CAO, sets them (nobody pays those) | 104 weeks at 70% of pay, at least the minimum wage for the first 52. Ends with your contract, and needs your cooperation with reintegration | Only if there is no employer. The Ziektewet is a safety net, not a second stage |
| Britain | None since 6 April 2026 | 28 weeks of Statutory Sick Pay. This is the whole statutory scheme, not a top-up | No state stage. Universal Credit or Employment and Support Allowance only after Statutory Sick Pay ends |
| Germany | None | 6 weeks at 100% of regular pay, after 4 weeks’ service | Week 7 |
| Slovenia | None | 30 working days at 80% of last month’s pay, capped at 80 working days a year | Day 31 |
| France | 3 before the state benefit, 7 before the employer top-up, both from day one (a collective agreement, the convention collective, may maintain pay through them) | 90% of gross for 30 days, then 66.66% for 30 days (opens in new tab) after 1 year’s service (opens in new tab), as a ceiling on your combined income, with the state benefit deducted from what the employer owes rather than added to it. Both stretches grow with service, capped at 90 days each (opens in new tab) | Day 4 |
| Spain | 3 (unpaid by statute, though a collective agreement, the convenio, may top them up) | Days 4 to 15 at 60% of the base (opens in new tab) | Day 16 |
| Ireland | None on a certified first illness once you have 13 weeks’ service (your 5 employer days cover them); 3, unpaid, after they are used or before 13 weeks | The statutory minimum (opens in new tab) of 5 days a year at 70%, capped at €110 a day in 2026, after 13 weeks’ service (opens in new tab) | Day 6 on a first illness, day 4 once the 5 days are used |
| Italy | 3 (your contract decides: employer-paid where the collective agreement, the CCNL, provides for it, unpaid where it does not; not covered by statute) | None beyond those 3 days. The employer advances the state money from day 4 | Day 4 |
| Portugal | 3 (paid by nobody) | None | Day 4 |
In the Netherlands your illness is, legally, your employer’s problem for two years, and article 7:629 of the civil code (opens in new tab) is where that comes from. The Ziektewet, the state sickness benefit, is what comparison tables print as “the Dutch state scheme”, and it is the safety net for people with no employer to carry them. That means agency staff whose contract ends mid-illness, and anyone already drawing unemployment benefit when they fall ill. It is not what happens after the two years. It is what happens instead. After week 104 you move to WIA, the long-term scheme UWV runs for people who cannot work, on tests of its own.
None of those two years is unconditional. Refuse suitable work, or the return-to-work steps your employer sets, and the right goes; hold back information they need and payment stops until you hand it over. It cannot outlive the contract either. A fixed-term employee gets it for the remaining term, and the Ziektewet then takes over from the first day of incapacity after the job ends.
Portugal sits at the other end, where the cost is three unpaid days and no employer money at any point. The labour code (opens in new tab) treats sickness as a justified absence that still costs you your pay, on the reasoning that social security covers it. Social security does not cover the first three days. Those belong to nobody.
Nobody designed those two systems to sit on the same continent. They do, and they will next year as well.
Germany runs the strongest first month here, six weeks (opens in new tab) at 100% of your regular pay (opens in new tab) and no waiting days, with Slovenia’s employer (opens in new tab) next. A German employee who falls ill in the first four weeks of a job has no claim on the employer. The health insurer will usually pay Krankengeld instead, though whether it does depends on the individual case.
France makes you wait twice over rather than twice in a row. Both waits run from the first day off, so the state pays from day 4 and the employer from day 8, and the first three days are paid by nobody. The top-up needs a year’s service and grows by ten days per further five years. A collective agreement can beat all of it, including the three unpaid days, the seven-day wait and the service condition.
Italy needs reading twice. INPS (opens in new tab), Italy’s social security institute, says the first three days are “entirely at the company’s expense, if the employment contract provides for it”. Your collective agreement decides whether it does. Where it does not, those three days are unpaid and the statute will not rescue them.
Ireland has the oddest arithmetic of the nine. Spend your five paid sick days on a first illness and the state picks up at day 6. Fall ill again later in the same year with those five gone and you meet the bare three waiting days, so nothing arrives until day 4 (opens in new tab). Same worker, same year, two different day-one outcomes. The rule is working exactly as written.
What does the scheme actually pay, and what caps it?
A percentage of your usual pay, and then a ceiling over it in most markets; Ireland pays flat weekly bands instead, and Britain the lower of a flat weekly amount or 80% of earnings.
| Market | Scheme (native name) | State rate | State ceiling | State duration |
|---|---|---|---|---|
| Netherlands | Ziektewet (opens in new tab) | 70% of the dagloon, the assessed daily wage | €309.91 gross a day from 1 July 2026 | 104 weeks (opens in new tab) counted from day 1, employer stage included |
| Britain | Statutory Sick Pay (opens in new tab) | No state stage: the employer pays all 28 weeks, at the lower of £123.25 a week or 80% of normal weekly earnings | £123.25 a week, 2026/27 | 28 weeks, all of it employer-paid |
| Germany | Krankengeld (opens in new tab) | 70% of gross pay, capped at 90% of net | €193.75 a day of assessable pay in 2026 | 78 weeks per three-year block for the same illness, and those 78 weeks include the 6 employer weeks, so about 72 weeks of cash |
| Slovenia | Nadomestilo plače (opens in new tab) | 80% of the base, rising to 90% after 90 days for ordinary illness. The base is your average monthly pay across the previous calendar year, not this month’s. 100% for a work injury or occupational disease | 2.5 times the last known average monthly gross wage, which was €6,705.90 for absence in July 2026, re-set every month | No statutory maximum for your own illness |
| France | Indemnités journalières (opens in new tab) | 50% of the daily base | €42.97 gross a day for stoppages prescribed from July 2026 | 360 days over three years |
| Spain | Incapacidad temporal (opens in new tab) | 60% of the base from day 4, 75% from day 21. The base for ordinary illness is a daily figure: last month’s contribution base divided by the days it covered. Days 4 to 15 come from the employer, not the state | Contribution base capped at €5,101.20 a month in 2026 (opens in new tab) | 365 days, extendable by up to 180 more only if the INSS expressly grants it |
| Ireland | Illness Benefit (opens in new tab) | Flat weekly bands, not a percentage | €254.00 a week on average weekly earnings of €300 or more, down to €114.00 under €150, across four flat 2026 bands | 624 days with 260+ weeks paid, 312 days with 104 to 259 |
| Italy | Indennità di malattia (opens in new tab) | 50% from day 4 to 20, 66.66% from day 21 to 180 | None identified for employees | 180 days per calendar year |
| Portugal | Subsídio de doença (opens in new tab) | 55% to day 30, 60% to day 90, 70% to day 365, 75% beyond | No cash ceiling, and a floor of €9.20 a day in 2026, which tracks the minimum wage | 1,095 days |
Figures checked against each national authority on 29 July 2026. Slovenia’s ceiling is re-set every month, France’s moves with the minimum wage, and Ireland’s bands are set annually and due to be revisited at Budget 2027, so check the current figure with the paying institution before you rely on it.
The percentage is the part people remember. The ceiling is the part that decides what lands in the account, and above it the percentage stops describing you at all.
Every figure here is gross. Sick pay is generally taxable replacement income, and Germany is the sharpest departure. Krankengeld, the sickness benefit the statutory health fund pays, is free of income tax but still pushes up the rate on your other income, and still has pension and care contributions taken off it. Ireland exempts Illness Benefit from USC and PRSI but not from income tax.
France is the clearest case of a ceiling doing the real work. The state pays 50% of your daily base, which sounds survivable until the cap arrives at €42.97 gross a day. It is low because only salary up to 1.4 times the monthly minimum wage counts, and for stoppages beginning on or after 1 July 2026 that is €2,613.83 gross a month.
Put a number on it. Take an employee on €3,500 gross a month; the salary is invented, the rest of the figures are not.
- Capped base: €2,613.83, not €3,500, because only 1.4 times the minimum wage counts.
- Daily base: €2,613.83 x 12 / 365 = €85.93 a day.
- Daily cap: 50% of €85.93 = €42.97, exactly the published maximum.
- A later month, 30 paid days: €1,289.10 gross.
- The first month, 27 paid days after the three-day wait: €1,160.19 gross.
- Against the €3,500 they actually earn, the 50% they were promised is 37% in that later month and 33% in the month they fall ill.
That is the state benefit on its own. It is also all you get if you have under a year’s service, because the employer top-up does not apply. With a year in, the employer has to bring the combined total to 90% of gross, and the state benefit is deducted from what it owes rather than added to it.
Germany reads better and carries a trap. 70% of gross, capped at 90% of net, on pay up to €193.75 a day in 2026 (opens in new tab), a daily ceiling the social code sets out separately (opens in new tab). If you have read “six weeks, then 78 weeks” somewhere, that is wrong by six weeks. The 78 include the six.
Ireland is not a percentage at all. Four flat weekly bands in 2026: €254.00 on average weekly earnings of €300 or more, then €198.90 (€220 to €299.99), €163.70 (€150 to €219.99) and €114.00 (under €150). Above the top band whatever you earned is gone. There are increases for an adult dependant and for children, but both are tested against your partner’s income, so don’t budget on them until you’ve checked. There is no version of this where somebody else checks it for you.
Portugal escalates, and the 70% that most tables print is the band that begins in month four. Your first month is 55%. The €9.20 daily floor is 30% of the €920 monthly minimum wage and moves whenever that does. Those first two bands rise by 5 percentage points, to 60% and 65%, if your reference pay is €500 a month or less. The same 5 points apply if your household has three or more children under 16, or under 24 if they are on child benefit. The two uplifts do not stack, and neither reaches the 70% or 75% bands.
Spain’s 365 days can also end the other way. At that mark the INSS may sign you off as fit instead, or open a permanent-incapacity assessment.
Italy’s 180 days are counted per calendar year, so the clock resets on 1 January instead of rolling.
Slovenia’s ceiling will date fastest. It is 2.5 times the last known average monthly gross wage, which put the ceiling at €6,705.90 for absence in July 2026, and it is re-derived every single month. That’s the entire thing.
Who qualifies for sick pay, and by when must you report it?
Four markets ask only that you are insured or employed, four want a contribution record, Italy turns on your employee category, and the deadline runs from 48 hours in France to six weeks in Ireland.
| Market | Deadline to tell them | If you are late | Contribution or service record |
|---|---|---|---|
| Netherlands | Tell the employer on day 2 (opens in new tab). The employer tells UWV by day 4 | UWV back-pays, capped at one year. The employer can be fined up to €455 (opens in new tab) | None |
| Britain | Your employer’s own deadline, or 7 days (opens in new tab) if they have not set one | You could lose some of your Statutory Sick Pay. Raise it with your employer first, then HMRC’s Statutory Payment Dispute Team (opens in new tab) if that gets nowhere | None since 6 April 2026, when the Lower Earnings Limit was abolished |
| Germany | 1 week (opens in new tab) to the Krankenkasse, unless your doctor has already sent the data electronically, which normally happens | The entitlement rests, and the 78-week clock keeps running | None. Being insured is the only test |
| Slovenia | No claim by you (opens in new tab). The doctor certifies and the employer files | Not applicable to you | None |
| France | 48 hours (opens in new tab) to send the certificate | Not published by the Assurance Maladie, so treat the 48 hours as hard | 150 hours in 3 months, or 1015 times the hourly minimum wage over 6 months. Harder after 6 months off |
| Spain | Five years (opens in new tab) to claim, but payment backdates only 3 months | You lose everything older than 3 months | 180 days of contributions in the last 5 years for ordinary illness, none at all for an accident |
| Ireland | 6 weeks (opens in new tab) | You may lose some of the payment. Backdating needs a good reason | 104 weeks paid since you first worked; plus 39 weeks paid or credited in the relevant tax year, of which 13 paid; or 26 paid in that year plus 26 in the year immediately before |
| Italy | Nothing, if the doctor files electronically. 2 days from the date of issue if you are handed a paper certificate | A day of benefit is forfeited for each day of unjustified delay | None stated for permanent industrial and service employees. Fixed-term and other categories have their own tests |
| Portugal | 5 working days (opens in new tab) | You keep the right, but payment starts from the day it arrives | 6 calendar months of contributions, and 12 days worked in the 4 months before last |
Two days. That is what Italy gives you when the electronic route fails and the doctor hands you paper instead. Two days from the date the doctor issued it to get it to INPS, and a day of benefit is forfeited for each day of unjustified delay (opens in new tab). The electronic route is the normal one, and paper is for exceptional cases.
Ireland gives everybody six weeks either way.
Lateness in Germany does not cancel the claim. The entitlement rests while the 78-week clock keeps running underneath it, so you lose the cash and the days as well. Spain gives you five years to claim and then backdates payment three months, which is a five-year deadline behaving like a three-month one. Portugal’s five working days cost you the days before the certificate arrives, not the right itself.
The record tests are where the systems part company hardest. Germany, the Netherlands, Slovenia and Britain ask for nothing beyond being insured or employed, and Italy asks nothing of permanent industrial and service employees, though other categories have their own tests. The remaining four want a contribution record, and Ireland wants two at once. None of that is memorable, and nobody expects you to hold it in your head. It is in the table when you need it, and it will still be there tomorrow.
If you have paid in elsewhere in the EU, your new country must count those periods, so far as it needs them, when it checks your qualifying record (Article 6 of Regulation 883/2004 (opens in new tab)). Moving between Britain and an EU market runs on a different instrument, the EU-UK Trade and Cooperation Agreement’s Protocol on Social Security Coordination, and its Article SSC.7 does the same job. Either way the institution has to trace the periods, but you have to tell it they exist. Counting periods is not the same as merging schemes: the coordination rules settle which country covers you, and then that country’s own rules apply in full. The same holds for what these nine states pay when the job ends instead.
What if you work for yourself?
Badly, in four of the nine.
| Market | If you work for yourself |
|---|---|
| Netherlands | Excluded in practice. Private income-protection cover is the normal route, and it is not an entitlement |
| Britain | Excluded (opens in new tab). Statutory Sick Pay requires employee status, so the fallback is Universal Credit or Employment and Support Allowance |
| Germany | Opt-in (opens in new tab), and then paid only from week 7 (opens in new tab) |
| Slovenia | Covered, treated as employees, and self-funding the first 30 working days (opens in new tab) |
| France | Covered by their own scheme. 12 months’ affiliation, maximum €65.84 a day, set on 1 January 2026 (opens in new tab) |
| Spain | Covered, and cover is compulsory (opens in new tab). Same 60% then 75% |
| Ireland | Excluded. Illness Benefit is not paid on the self-employed PRSI class (opens in new tab) |
| Italy | Mostly excluded, apart from Gestione Separata |
| Portugal | Covered. 10 waiting days, and 365 days maximum (opens in new tab) |
France pays a self-employed claimant up to €65.84 a day and an employee up to €42.97. The self-employed maximum is the higher of the two, which is not the way anyone expects this to go.
The Dutch route is private income-protection cover, which is voluntary, individually underwritten, and can be priced up or refused on health grounds.
Excluded from sick pay is not the same as excluded from everything. The means-tested routes are separate, and they are not covered here.
If you are self-employed in the Netherlands, Britain, Ireland or Italy, sick pay is not the thing that will catch you. How much cash to keep within reach is a more useful question than which percentage applies to somebody else, and the emergency fund calculator puts a number on it.
What changed in sick pay rules in 2026?
The newest change here is British, and it landed in April. On 6 April 2026 Britain removed the three waiting days and the Lower Earnings Limit, the earnings floor that used to shut low earners out of the scheme entirely. S.I. 2026/373 commenced section 10 (opens in new tab) and section 11 (opens in new tab) of the Employment Rights Act 2025.
A British worker off sick for a single day is now in a period of incapacity for work, so a two-day absence is paid where it would once have got nothing. If you are reading a British sick-pay guide written before April, it will tell you the first three days are unpaid. They are not.
Slovenia’s change is older and much easier to get wrong. The employer-paid period went from 30 working days to 20 and back to 30, restored by ZIUZDS (opens in new tab) from 1 January 2024. The consolidated text of the older health-insurance act still says the health fund takes over on day 21. It takes over on day 31, and checking that one act alone leaves you out by ten working days.
One of the other seven has an open end. The Netherlands has a compulsory sickness scheme for the self-employed, BAZ, which is a proposal aimed at 2029 rather than enacted law, and if it does arrive it would date the line above about private cover. For the remaining six, none identified, which is not the same as none exists. These rules move by finance act and ministerial order, quietly, in the week nobody is looking.
What can you do from bed today?
Most of this isn’t fixable from bed. Two things are.
If you are ill right now, do the notification first. The third table has your market’s deadline: in the Netherlands, Britain, France, Italy and Portugal it is a matter of days, and in Germany a week. Then read one row, your own, in the first table. What your employer owes before the state starts is what covers the month you’re actually in, and it is the part no comparison prints.
The paperwork can wait. When you are upright, find your collective agreement if you have one, or else your contract. Read the sick-pay clause; in Italy it is the only thing standing between you and three unpaid days. And staying financially steady through the worry that arrives with a diagnosis is its own piece of work, not something solved by reading nine social security systems in one night.
Then leave it alone. The rest will keep. You didn’t fail to plan for this. Nobody expected you to have memorised any of it before you got ill.
Frequently asked questions
Who pays sick pay in Europe, your employer or the state?
How many waiting days are there before sick pay starts?
How much does the state pay when you are off sick?
Do the self-employed get sick pay in Europe?
Sources (41)
- MISSOC: comparative tables on social protection
- Wetten.overheid.nl: Burgerlijk Wetboek Boek 7, artikel 629
- UWV: maximumdagloon
- GOV.UK: Statutory Sick Pay, what you'll get
- Legislation.gov.uk: Employment Rights Act 2025, section 10
- Gesetze im Internet: Entgeltfortzahlungsgesetz § 3
- Gesetze im Internet: SGB V § 47, Krankengeld
- Gesetze im Internet: SGB V § 223, the daily contribution ceiling
- Gesetze im Internet: SGB V § 49, when the entitlement rests
- Gesetze im Internet: German social insurance reference values for 2026, § 2
- PIS RS: the Slovenian statute setting the employer-paid sick leave period
- PIS RS: ZIUZDS, restoring the 30 working day employer period from 1 January 2024
- ZZZS: nadomestilo plače med začasno zadržanostjo od dela
- ZZZS: višina nadomestila plače
- Code du travail: article L1226-1, the service condition for the employer top-up
- Code du travail: article D1226-1, employer top-up rates
- Code du travail: article D1226-2, top-up duration by length of service
- Ameli: indemnités journalières pour maladie, salarié
- BOE: Spanish General Social Security Act, consolidated text BOE-A-2015-11724
- Seguridad Social: incapacidad temporal
- Seguridad Social: contribution bases and rates for 2026
- Irish Statute Book: Act No. 24 of 2022, statutory sick leave
- Citizens Information: Illness Benefit
- Gov.ie Department of Social Protection: Illness Benefit
- INPS: indennità di malattia e visite mediche di controllo
- Diário da República: Código do Trabalho, consolidated text
- Segurança Social: subsídio de doença
- Diário da República: Decreto-Lei 28/2004, sickness protection regime
- EUR-Lex: Regulation (EC) 883/2004 on social security coordination, consolidated
- Wetten.overheid.nl: Ziektewet
- Assurance Maladie: sick leave for self-employed artisans and traders
- Citizens Information: statutory sick leave and sick pay
- Citizens Information: social insurance (PRSI) classes
- Gesetze im Internet: EFZG, paragraph 4
- Gesetze im Internet: SGB V, paragraph 44
- Gesetze im Internet: SGB V, paragraph 46
- HMRC: Statutory Payment Dispute Team contact page
- GOV.UK: Statutory Sick Pay eligibility
- Legislation.gov.uk: Employment Rights Act 2025, section 11
- Seguridad Social: temporary incapacity cover for self-employed workers
- ZZZS: conditions for sick-leave compensation
— That's the lot. It is now night.
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By Jure Jaklič
Founder and editor of Money Owl. Data analyst by trade; personal finance learned first-hand across six European countries.
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