How to manage leave across multiple countries: the complete guide for international teams (laws, holidays, carry-over)

Short answer: to manage leave across multiple countries, keep one process (request, approve, shared calendar) and let the rules follow the person: each employee gets the statutory minimum, public holidays, working week and counting method of the country where they habitually work, written down in a one-page rule sheet per country with a named owner. Decide the governing law first, plan carry-over and exit payout per country, give every team a local approver with a backup, and keep everyone on a single wall chart. A leave tool that assigns holidays and working weeks per person (Bueggio HR does, for 47 countries, from €1.30 per user per month) turns the rule sheets into balances nobody has to recompute by hand.

The first hire outside your home country changes leave management more than the next fifty hires at home. Picture a 40-person company run from London: a sales team in Dublin, two engineers in Berlin, a customer success lead in Madrid and a US account manager working from Austin. Five people, five statutory minimums, five sets of public holidays, at least two ways of counting a day off, and two continents of time zones between the person asking and the person approving. None of it is exotic; all of it breaks a spreadsheet that has one "holidays" column and one allowance for everyone.

This guide is the how-to: whose law applies, what to write down per country, how to handle holidays, counting, carry-over and leavers, and how to approve across time zones without a day of delay. If you are still choosing a tool, our ranking of the best multi-location leave management tools compares six of them side by side; if your team is fully remote rather than spread over offices, the guide for remote teams is the closer fit. This is operational guidance, not legal advice: confirm anything contractual with an employment lawyer in each country.

Why several countries is a different problem, not a bigger one

A single-country company has one set of answers. Every new country reopens five questions at once:

• Entitlement. The UK minimum is 5.6 weeks, Ireland's 4 working weeks, Spain's 30 calendar days, the United States has none at federal level. Company policy sits on top of each.
• Public holidays. Easter Monday is a day off in London, Dublin and Berlin and a normal working day in Austin. Germany adds holidays state by state; Spain region by region and town by town.
• Counting. A "day" of leave is a working day in the UK, a calendar day in Spain and, in France, possibly a jour ouvrable that includes Saturday.
• Leave year, carry-over and exit. Germany lets untaken leave run to 31 March, France traditionally runs its leave year from 1 June, and every country has its own rule on paying out leave when someone leaves.
• Who approves, and when. A request sent from Austin at 9am lands in London at 3pm; with one central approver, half your requests wait a night.

Statutory minimums and public holidays at a glance

Start from the floor. The table below summarises the legal minimum for a full-time employee on a five-day week and the public-holiday picture in the countries our customers combine most often. Collective agreements and contracts usually add more; nothing here can be reduced by contract.

Two rows deserve a second look. In the UK the 28 days can include bank holidays, so "25 days plus bank holidays" is a generous contract, while "28 days including bank holidays" is the legal floor. In Spain the 30 days are calendar days, which on a five-day week works out at roughly 22 working days: comparing "30" in Madrid with "25" in London is comparing different units.

Step 1: decide whose rules apply to each person

The question is not where your headquarters is; it is where each person habitually works. Inside the EU, the Rome I Regulation (article 8) lets the employment contract choose its law, but the choice cannot deprive the employee of the mandatory protections of the country where they habitually carry out their work. A developer living and working in Berlin on a London contract keeps at least the German statutory minimum; giving them the UK handbook does not change that.

• Local employees of a local entity follow local law and any local collective agreement. Easy case.
• Posted workers, sent abroad temporarily, keep their home contract, but the Posted Workers Directive guarantees them the host country's minimum paid annual holidays during the posting.
• Remote employees abroad are where most small companies get caught: someone who moves to Lisbon "for a year" may become a Portuguese-law employee in practice. Decide case by case, and remember that social security and tax follow their own rules.
• Employer of record (EOR) staff are legally employed by the EOR, which handles local contracts and payroll. You still need their absences on your calendar: agree who records them and who approves.
• Contractors have no statutory leave, but their unavailability still matters to planning. Track it as a non-deducting "unavailable" type, never as annual leave.

Write the answer down per person. A single "country" field on each profile, driving holidays and counting, prevents most of the mistakes that follow.

Step 2: one process, local entitlements

Employees should experience one way to ask for time off, wherever they sit: same app, same approval flow, same calendar. What differs is the entitlement underneath. Two models work:

• Local allowances. Each country gets its statutory minimum plus local market practice (25 days in the UK, 28 or 30 in Germany, 30 calendar days in Spain). Fair locally, but explain the basis openly, because people compare.
• A global floor. Everyone gets at least, say, 25 working days, and the local minimum applies wherever it is higher. Simpler to communicate; the rule to remember is that a global floor can raise a local entitlement but never lower it.

Whichever you choose, keep a one-page rule sheet per country with a named owner and a review date. It should answer: statutory minimum and company allowance, counting unit, public-holiday calendar (national and regional), leave year, carry-over limit and deadline, notice to book, treatment of sickness and parental leave, and payout on exit. When a law changes (Italy restored 4 October as a national holiday; France changed how leave accrues during sickness), you update one sheet and the balances, not twelve spreadsheets.

Keep sickness and parental leave separate from annual leave. They follow different laws in every country, they must never eat into holiday balances, and sickness records carry health data that deserves stricter access than "who is on holiday next week".

Step 3: let public holidays follow the person

The single most common multi-country error is a company-wide holiday calendar. If Dublin's St Patrick's Day is on the shared calendar, your Berlin engineers look absent; if it is not, your Irish team looks available on a day they are legally off. The fix is structural: each person follows the public-holiday calendar of the country where they work, and the shared wall chart shows everyone's own red days side by side.

• Add regional holidays. Germany has nine nationwide holidays and several more by state; Spain has national, regional (autonomous community) and two local holidays per town; the UK differs between England, Scotland and Northern Ireland.
• Add company closure days on top, such as the office shut between Christmas and New Year, and decide whether they consume allowance.
• Check substitute days. When a holiday falls on a weekend, the UK moves it to Monday, Spain lets regions move some, Italy and France simply lose it. Import the official calendar rather than copying last year's.
• Consider floating holidays if the gap between countries feels unfair: a fixed number of days people place on holidays that matter to them. Define who qualifies and whether they carry over.

Step 4: count days the local way

Balances only mean something if a day is counted the way the local law counts it. Give each person a personal working week (Monday to Friday, a four-day week, a Saturday shift) so a booking deducts only days they would actually have worked, and make sure the tool can count a half day both in the morning and in the afternoon. Then handle the national exceptions explicitly: France can count leave in jours ouvrables (Monday to Saturday) or jours ouvrés (the days the company works), Spain's statutory 30 days are calendar days, and Italy measures ROL and ex-festività in hours. Our explainer on how days are counted shows how working weeks, half days and holidays combine in one quote.

Step 5: leave year, carry-over and leavers

This is where multi-country companies lose money, usually at exit. Record three things per country:

• The leave year. Most countries are happy with the calendar year; France's legal reference period traditionally runs from 1 June to 31 May unless an agreement says otherwise. Pick one company leave year where you can, and note the countries where the law ties you to another.
• Carry-over. Within the EU, the four statutory weeks cannot be swapped for money during employment (Working Time Directive, article 7), and the Court of Justice (Max-Planck, C-684/16) ruled that leave can be lost at year end only if the employer actually encouraged the person to take it and warned them it would lapse. Germany carries untaken leave into the first three months of the next year; Italy requires two of the four weeks in the year they accrue and the rest within the following 18 months. Blanket "use it or lose it" rules are risky in Europe.
• Exit. Untaken statutory leave is paid out when employment ends across the EU and in the UK; in the US the answer depends on the state and on what your written policy promises. Our article on annual leave during the notice period covers the handover months, and the one on unused vacation days the year-end side.

Test the rule sheet with the awkward cases, not only full-year staff: someone who joins in October (pro-rata), someone who moves from Madrid to London mid-year, someone who leaves in February with leave carried over from last year.

Step 6: approve across time zones without waiting a day

One central approver for five countries is a bottleneck by design. Give each team or country an approver who shares most of its working hours, plus a backup for holidays and sick days, and let individuals who report across borders have a personal approver. Then remove the login step: when the approver can say yes from the notification email, from Slack or from Microsoft Teams, a request from Austin is decided before London closes. Set notice expectations per country and leave type (two weeks for annual leave, same day for sickness), and add an urgent route for emergencies.

Plan peaks before they happen. August empties offices in Spain, Italy and France while Germany staggers summer by state school calendar; Thanksgiving week thins out the US; the week between Christmas and New Year is busy everywhere. A cap on how many people per team can be away on the same day, and blocked dates for a launch or a year-end close in one country only, prevent the first-come-first-served scramble. Check coverage by function (who can answer a Spanish-speaking customer next Tuesday?), not just by office.

Step 7: keep leave data lawful everywhere

Leave data looks harmless until you notice what it reveals: a sickness absence or an attached medical certificate is health data, special-category data under GDPR article 9. With people in several countries, ask three questions of any tool: where is the data hosted (an EU region you can name, under a published data processing agreement), who can see what (colleagues see "away", not "sick"; certificates only for the people who need them), and can you export and erase one person on request. If part of the team is in the US, the data still belongs to an EU-governed controller for your EU employees, so EU hosting keeps the transfer question simple.

How to run all of this in Bueggio HR

Bueggio HR was built around the idea that rules follow the person, which is exactly what several countries need. A typical setup takes an afternoon:

1. Give each person a holiday country. The admin picks it in the person's profile from 47 preloaded national calendars (deliberately not self-serve), and the official calendar is imported in one click. From then on the wall chart, every booking quote and every balance use that person's holidays; regional calendars and company closure days are added on top. The public holidays guide walks through it.
2. Set a personal working week and allowance. Each person has their own working days, their own annual allowance, a start date for pro-rata first years, and allowance adjustments (plus or minus days with a written reason) for local carry-over or migrated balances. Statutory mechanics for Italy, France and Spain (ROL and ex-festività hours, RTT, convenio days) are built in. See managing people.
3. Model countries or teams as departments. Each department has its own approver, an optional cap on simultaneous absences and its own date locks; anyone can have a personal approver override.
4. Approve from wherever the approver is. One click from the notification email, from Slack or from Microsoft Teams, no login, in the approver's own language (English, Italian, French or Spanish, per user).
5. Share one picture. The wall chart shows every country on one screen, approved leave syncs to Google Calendar and Outlook, each department has an iCal feed, and a daily "who's off" summary can post to each team's Slack channel. Reports filter by department, and the monthly payroll export lists approved absences for every country in one file.

Data is hosted in Frankfurt under a published DPA, with self-serve GDPR export and erasure. The honest limit: the leave year, the carry-over policy and the time zone used for reminders are set once per company, so a country that legally needs a different leave year is handled with allowance adjustments rather than a separate policy. Pricing is one plan at €1.30 per user per month, everything included, and the first month is free with no card.

Frequently asked questions

How do you manage employee leave across multiple countries?

Run one request-and-approval process for everyone and let the entitlement rules differ by country. In practice: decide which country's law governs each contract (usually where the person habitually works), write a one-page rule sheet per country (statutory minimum, public holidays, counting unit, leave year, carry-over, payout on exit), give every person their own holiday calendar and working week in a single tool, name a local approver with a backup, and keep sickness and parental leave separate from annual leave. A shared wall chart then shows who is away across all countries on one screen.

Do remote employees abroad get the leave rules of the company's country?

Not automatically. In the EU, the Rome I Regulation lets the contract choose its law, but that choice cannot take away the mandatory protections of the country where the employee habitually works, so a person living and working in Germany keeps at least the German statutory minimum even on a UK or Italian contract. Posted workers get the host country's minimum paid holidays. Check each case with a local adviser, and model the result per person in your leave tool rather than per company.

What happens to unused annual leave when an employee leaves, in different countries?

Inside the EU the statutory four weeks cannot be replaced by money during employment, but untaken leave must be paid out when employment ends (Working Time Directive, article 7). The UK also pays untaken statutory holiday on exit. Germany allows carry-over into the first three months of the next year and pays out at termination. In the United States there is no federal rule: payout depends on the state and on your written policy. Record the exit rule in each country's rule sheet before the first person leaves.

The bottom line

Managing leave across multiple countries is not about one perfect global policy. It is one simple process on top of rules that are allowed to differ: the law of the place where each person works, a one-page rule sheet per country, holidays and working weeks attached to the person, carry-over and exit decided before anyone leaves, and approvers who can say yes from their inbox. Get those right and the wall chart does the rest. For the wider picture, read our complete guide to leave management software and the checklist for choosing a leave management system, then try Bueggio HR with two countries on a real month of requests.