The Global Landscape of Working Time Regulations: A Comparative Analysis

A shifting paradigm: Spain’s working hours reform in context

Spain is poised to redefine its working time regulations, reigniting discussions on how nations regulate maximum working hours and mandatory rest periods. While most countries impose some form of restriction on weekly and daily working hours, the specifics vary widely based on economic structure, historical labour movements, and cultural attitudes toward work-life balance.

For companies managing international employee mobility, understanding these differences is critical — not only for compliance but also for structuring competitive compensation packages and effectively managing global workforces.

To provide a data-driven perspective, we have conducted a comparative study on maximum working hours across several key economies. Our primary sources include:

• first-hand insights from Baker Tilly International’s Global Mobility Committee, reflecting expert interpretations of local labour laws.
• official government sources, including national labour codes and international regulations.

Below, we examine legal maximum working hours (both per week and per day) and mandatory rest periods across a selection of key jurisdictions.

Maximum working hours and rest periods: a global comparison

While international labour standards, particularly those set by the International Labour Organisation (ILO), encourage reasonable work limits, national legislation remains highly diverse. The following comparative insights highlight key trends and differences.

Europe: harmonised yet diverse

The EU Working Time Directive sets a 48-hour weekly cap (including overtime) averaged over a reference period, mandates 11 hours of daily rest, and requires at least one full day off per week. However, national implementations vary significantly.

• France – a 35-hour workweek acts as an overtime threshold, but the legal maximum remains 48 hours, with a daily cap of 10 hours.
• Germany – standard workweek is 40 hours, extendable to 48 hours with overtime, and a daily limit of 10 hours.
• UK – Employees can opt out of the 48-hour limit, allowing for more flexibility, though rest period regulations remain in place.
• Switzerland – enforces a 45-hour workweek, extendable to 50 hours in certain industries.

North America: freedom vs. protection

• United States – no federal limit on working hours. Employers must pay overtime beyond 40 hours per week, which acts as a regulatory deterrent, but no daily or weekly rest periods are mandated.
• Canada – follows a 40-hour workweek standard, with a maximum of 48 hours including overtime.

Asia: structured yet demanding

• Singapore – legal working hour limits apply only to specific employees under Part IV of the Employment Law (manual workers and certain non-manual workers). Executives and professionals are exempt.
• Japan – enforces a 40-hour workweek, with overtime permitted up to 45 hours per month.
• China – standard workweek is 40 hours, with an extension up to 44 hours in some cases.
• India – follows a 48-hour weekly cap, with strict overtime regulations.

Australia and Latin America: evolving policies

• Australia – one of the shortest standard workweeks at 38 hours, with reasonable overtime permitted.
• Brazil and Latin America – many countries maintain a 44-hour week with strict weekly rest requirements.

The global outlook: a shift toward flexibility?

As Spain considers reducing working hours, broader global trends lean toward flexibility rather than rigid limits. Some nations enforce strict work-hour caps and mandatory rest periods, while others rely on employer discretion and overtime compensation.

For companies engaged in global mobility, this evolving landscape presents key considerations:

1. Ensuring compliance with local regulations to mitigate legal risks.
2. Adapting employment contracts and benefits to remain competitive across different markets.
3. Understanding regional labour law differences to optimise international assignments and workforce planning.

The debate on working time regulation is far from over. The question remains: will more nations follow Spain’s lead, or will the global market continue to prioritise flexibility over rigid limitations?