Sickness, how rules and protection change in Europe: who pays and for how long

But how does it work in other European countries? The picture is very heterogeneous. While in some states the first few days of sick leave are unpaid in order to discourage abuse, in others financial coverage kicks in immediately. Differences also emerge on the bureaucratic front: alongside fully digitalised systems there are procedures that require certificates, authorisations and repeated visits. Here is an overview of the main rules in force in some European countries.

In Romania, from February 2025, the first day of sick leave is no longer paid. The government justified the decision with the need to counter the phenomenon of absences deemed fraudulent. After protests and public debate, the parliament intervened by introducing some exceptions: hospitalised patients, medical emergencies and people suffering from serious chronic illnesses continue to receive compensation from the first day. For all other workers, however, the pay cut on the initial day of absence remains.

The Romanian system is characterised by a strong bureaucratic component. To obtain a sickness certificate, the employee must present the doctor with a declaration from the employer certifying the payment of health insurance contributions and stating the number of sick days already used in the current year. It is also necessary to show the health card and validate it in the computer system. The State does not have a single database that collects this information.

The management of prolonged absences also requires several steps. The general practitioner may grant a maximum of seven sick days for the same illness; for longer periods, the employee must obtain a specialist examination and a new authorisation. The ordinary limit is 183 days per year, although there are exceptions for serious illnesses such as cancer and tuberculosis.

In France, the system provides for a waiting period that leaves the worker without benefits during the first days of absence. In fact, social security benefits start after three days, while those that may be supplemented by the employer generally start after seven days, unless more favourable conditions are laid down in collective agreements.

The administrative process is relatively simple: the doctor issues the certificate and the employee sends it to the employer. Absences can be covered for six months and, if there is adequate medical documentation, also for longer periods.

In recent years, the topic of sick leave has entered the centre of public debate. According to a study by Axa, the number of sick days increased by 50 per cent in 2019. The government has announced more thorough checks, especially on absences of more than one month, verifying the consistency between diagnosis, care pathways and medical prescriptions.

In Austria, employers may require a medical certificate even from the first day of absence, although many collective agreements only provide for an obligation from the fourth day. During illness, the employee initially continues to receive full salary; subsequently the health insurance system takes over, which can guarantee financial support for up to 26 weeks, extendable in some cases to 78 weeks.

Obtaining the certificate is considered relatively straightforward, but procedures become more complex in long-term absences, when the cost gradually shifts from the employer to the social security system.

In 2024, a broad public debate opened on the possibility of making the first day of sick leave unpaid. The proposal, supported by some business organisations, was opposed by the trade unions and the Chamber of Labour, which pointed out the risk of pushing employees to work even when sick. However, the debate did not result in legislative changes.

Among the most digitised systems is that of Lithuania. There are no days of absence: the employer pays for the first two days of absence, and from the third the public fund Sodra intervenes. The certificates are fully electronic and are automatically transmitted to both the employer and the social security institutions.

There is no strict annual limit, but absences of more than 122 consecutive days trigger a check on long-term capacity to work. To counteract possible abuses, the social security system may subject the worker to a second medical evaluation.

In Spain, the first three days of sick leave for common illnesses are unpaid, unless supplemented by collective agreements. From the fourth to the twentieth day, 60% of the wage base is paid, rising to 75% from the twenty-first day onwards. For accidents at work and occupational diseases, on the other hand, pay starts immediately.

The procedure is almost entirely digitalised: the certificate is transmitted directly by the doctor to the social security authorities and the employer. The ordinary maximum duration of illness is 545 days, extendable in special cases up to 730 days.

The country recorded a new record in sickness absence in 2025. Particularly significant is the growth in absences attributable to mental health problems, which have overtaken orthopaedic diseases as the second most common cause of absenteeism. Businesses and trade unions are divided over the causes: the former call for stricter controls, the latter draw attention to the deterioration of the healthcare system and the ageing of the working population.

In Bulgaria, insured workers receive an allowance of 80 per cent of gross salary during illness, rising to 90 per cent in the case of an accident at work or occupational disease. In order to qualify for the benefit, it is generally necessary to have accrued at least six months of contributions.

According to data for 2025, expenditure on sickness benefits reached almost EUR 550 million, or about 0.5 per cent of national GDP. Absences affected 965 thousand workers and covered over 16.7 million working days. The most frequent illnesses were viral infections and respiratory diseases.

In Poland, every day of sick leave is paid. The first 33 days are paid by the employer, thereafter by the ZUS social security institution. The allowance is 80% of the average salary for the last 12 months and can be paid up to a maximum of 182 days per year.

Since 2018, the entire procedure has been digitised: the doctor transmits the certificate directly to the social security agency. However, checks against abuse remain very frequent. In the first quarter of last year, 227,000 checks were carried out, which led to the suspension of almost 15,000 benefits.

Since 2025, however, the legislation has been softened, allowing the worker on sick leave to carry out normal daily activities, such as shopping or taking the children to school, without automatically losing entitlement to the allowance.

In Greece, the system provides for a three-day exemption during which the employer pays only half the daily wage. Thereafter, the EFKA social security agency intervenes. The maximum duration of benefits varies according to contribution history and can be up to 720 days in the most complex cases.

The main critical issue is bureaucracy: in order to obtain certification, the opinion of a private doctor is not sufficient, but it is necessary to apply to doctors affiliated with EFKA, with often long waiting times.

*This article is part of the gEuropean collaborative journalism "Pulse"and was contributed by Alina Neagu (HotNews, Romania), Francesca de Benedetti (Voxeurop, France), Natascha Ickert (Der Standard, Austria), Krasen Nikolov (Mediapool, Bulgaria), Ana Somavilla (El Confidencial, Spain), Lena Kyriakidi (EfSyn, Greece) and Emilia Bromber (Gazeta Wyborcza, Poland).