In Sweden, fathers are offered up to 16 months paid paternity leave after the birth of a child, the most generous in the world, during which time they are paid 80% of their gross salary, up to a ceiling of about 30,000 pounds. In Britain, by contrast, they are offered two weeks after the birth at (low) statutory level. The extreme disparity between those approaches reflects broad differences across Europe, and around the world, on an issue that is currently being hotly debated, both in the European parliament and at Westminster.

The European Commission has promised to bring forward proposals for new legislation on paternity, adopting and filial leave but this has so far failed to materialise. As a result, the Greens in the European Parliament have worked hard to ensure that a review of the existing legislation on protection for pregnant workers extends provision to include paternal rights.

Caroline Lucas, the Green Party leader, is the Green Group’s shadow rapporteur (draftsperson) for the legislation in the European Parliament Women’s Committee. She is supporting efforts by the committee rapporteur, the Portuguese Socialist Edite Estrelle, to improve the European Commission’s updating of the current rules on maternity leave. Their joint efforts have resulted in the Women’s Committee adopting a position that supports all women being offered a minimum of 20 weeks continuous leave before and after a birth (or adoption), with at least six after birth fully paid. (In fact the European Greens are going further in seeking 24 weeks.)

The committee is also asking for a guarantee of fully paid leave, non-transferable, of at least two compulsory weeks to be taken after the birth, for the mother’s spouse or partner. Adding in clauses on paternity leave provision to legislation on pregnant workers has proved particularly controversial with the Christian Democrats in the Parliament (a grouping with no UK representatives although Conservative MEPs tend to vote along similar lines).

In Britain, meanwhile, the Department for Business Innovation and Skills is consulting* (submissions must be in by 20 November) on a proposal to extend paternity leave up to 26 weeks (half of it paid at the statutory rate of about 120 pounds a week), allowing it to be taken after the mother has taken the first 26 weeks of leave (and in lieu of her taking her second 26 weeks). After that any paternity leave would be unpaid. The government is proposing that this take effect from April 2011.

Predictably, employers’ groups have complained about the “inconvenience” and “administrative burden” of the plan, restricted and restrictive as it is.
Extended paternity rights were promised in Labour’s 2005 general election manifesto, with a “goal” to extend paid maternity leave to a full year, which the government has now backed away from.

While any step towards recognising the importance of accepting that children aren’t simply a mother’s responsibility is a positive move, it is a pity that these proposals are so restrictive that the government itself admits that fewer than one in 16 fathers are likely to take it up. Many of course will be unable to afford to do so, and others might prefer alternative arrangements – even perhaps for the father to take primary responsibility for the baby soon after birth, or else for the parents to make some shared arrangements.

It would be much preferable to have a flexibility mirroring that of the Swedish system, which both acknowledges parents’ shared responsibility (by ensuring that the parent taking the lesser share of the 16 months take a minimum of two months, or otherwise lose them), while otherwise allowing the parents to make their own arrangements. Also key to the Swedish approach is the payment of near-full salary levels, ensuring that parents are in a financial position to take the full period of leave available.

Even in Sweden, however, despite the equality of the arrangements, the society is a long way from achieving equality of leave taken, with fathers taking only about 20% of the time available. Commentators say that a major factor is the continuing inequality of pay: even in Sweden women earn only 84% of male pay, so for most families the financial sacrifice is greater if the father takes more time off.

There has been debate about the possibility of providing equality of leave for both parents; perhaps this would be a step towards society acknowledging a genuinely shared parental responsibility. Already in Sweden, even with the limited take-up, observers are commenting that they are seeing more fathers on the streets pushing prams, cradling bottles, in baby-change facilities. Making such activities an ordinary, everyday, “working day” experience for fathers could surely only be a positive step.