Which Leave Types Apply in the US, EU, and Ukraine, and How to Set Them Up per Office

A company with one office in Kyiv and one in Lisbon already has two labor codes to follow. Add a contractor in Texas and there is a third. The leave request form looks the same for all three people, while the rules behind it differ for each of them.

This guide lists which leave types exist in each of the three legal systems, where the law makes them mandatory, and how to turn those rules into per-office settings in Teamtopia. It is the practical companion to the design story on the Flatstudio blog: how the country-aware policy system was researched and designed.

TL;DR

• The US, EU, and Ukraine share about half of their leave types. The other half is region-specific: jury duty and safe leave in the US, carer's leave in the EU, additional leave for hazardous work in Ukraine.
• Unpaid leave exists in all three systems but with different limits: 30 days a year by agreement in Ukraine, 60+ days with 90 days' notice in Portugal, mostly company policy in the US with FMLA as the federal floor.
• In Teamtopia, a country preset switches on the right leave types for an office. Every preset value stays editable, and contractors can be placed under any country's rules.
• Six policy types are live today. The remaining types, the country presets, and the deep policy screens are in development. Custom leave types are planned.

What is unpaid leave?

Unpaid leave is a period when an employee stops working and stops receiving salary while the employment contract stays in force. The position is kept, seniority is usually preserved (with country-specific exceptions), and the employee returns to the same role when the leave ends.

It sits between two outcomes that most teams want to avoid: an employee who has run out of paid days and keeps working through a family emergency, and an employee who resigns because the company had no way to grant a pause.

For the employee, unpaid leave covers what paid leave does not: a relative's illness, a court date, a move, a long course, treatment, or burnout when the balance is already zero. For the employer, it keeps a trained person on the contract without salary cost during the absence, and it replaces verbal agreements with a documented request that appears in the team calendar.

When is an employer required to grant unpaid leave?

The answer depends on the country and, in the US, on the state. Three of the systems Teamtopia supports today:

	Ukraine	Portugal (EU example)	United States
Legal basis	Law on Leave, Articles 25 and 26	Labor Code, Article 317	FMLA (federal), state laws, company policy
Mandatory cases	Article 25 lists cases where the employer must grant it (e.g., veterans, disability, care for a sick child)	Study and training, with narrow grounds for refusal	FMLA: 12 weeks for family and medical reasons at employers with 50+ staff
By agreement	Article 26: up to 30 calendar days a year	Any duration by agreement	Company policy
Minimum length	None	More than 60 consecutive days	None
Notice	By agreement	90 days in writing	Company policy; 30 days for foreseeable FMLA leave
Martial law rule	No 30-day cap by agreement; up to 90 days mandatory for employees abroad or with IDP status	n/a	n/a
Counts toward seniority	Article 25 leave yes; Article 26 leave no (since December 2023)	Yes	Not defined federally

Sources: Law 3494-IX raised the Ukrainian Article 26 cap from 15 to 30 days on December 24, 2023. Portugal's rules are set in Article 317 of the Código do Trabalho. US federal rules come from the Department of Labor's FMLA fact sheet.

What types of leave exist in the US, Europe, and Ukraine?

Teamtopia's research compared 59 statutory and common leave types across the three regions and consolidated them into 30 preset types in six categories. The table marks each type as present (+), absent (−), or present in some countries or states only (±).

Category	Leave type	Ukraine	Europe (EU)	USA
Time Off	Annual Leave / Vacation	+	+	+
Time Off	Seniority / Extra Vacation Days	+	+	±
Time Off	Paid Time Off (PTO)	−	±	+
Time Off	Unpaid Leave / Personal Leave	+	+	+
Time Off	Public Holidays	+	+	+
Time Off	Bridge Days / Comp Time	+	+	+
Time Off	Sabbatical	−	+	+
Family & Care	Maternity Leave	+	+	+
Family & Care	Paternity Leave	+	+	+
Family & Care	Parental Leave (Childcare)	+	+	+
Family & Care	Adoption Leave	+	+	+
Family & Care	Carer's Leave (Ill Family Member)	+	+	+
Family & Care	School Activities Leave	−	−	+
Health	Sick Leave	+	+	+
Health	Medical / Disability Leave	+	+	+
Health	Blood / Organ Donation Leave	+	+	+
Health	End-of-life Care Leave	−	+	−
Civic Duty	Military Leave	+	+	+
Civic Duty	Jury Duty / Witness Leave	−	+	+
Civic Duty	Voting Leave	+	+	+
Civic Duty	Civil Defense / Volunteer Leave	−	+	±
Civic Duty	Union Activities Leave	+	−	+
Personal Events	Marriage Leave	+	+	−
Personal Events	Bereavement / Compassionate Leave	+	+	+
Personal Events	Relocation / Moving Leave	−	+	−
Personal Events	Religious Leave	−	+	±
Special Cases	Study / Training Leave	+	+	±
Special Cases	Weather / Force Majeure	−	+	±
Special Cases	Domestic Violence Leave	−	−	+
Special Cases	Garden Leave	−	+	+

Three notes on reading the table:

• Jury duty is marked minus for Ukraine because court service there falls under Article 119 of the Labor Code as a public duty with average earnings preserved, so it does not need a separate leave type. In the US it is a distinct type with state-level pay rules: Massachusetts requires employers to pay regular wages for the first three days, after which the state may pay $50 a day.
• Carer's leave is plus for all three, but only the EU guarantees it by directive: Directive 2019/1158 gives every worker five working days a year, unpaid unless a member state decides otherwise.
• Domestic violence leave (safe leave) is plus only for the US, where several states mandate it, though Australia and New Zealand run comparable schemes that Teamtopia uses as reference defaults.

Can a company run on unpaid leave only?

Yes, and many small teams do. Companies that work mostly with contractors, including individual entrepreneurs (FOP) in Ukraine, have no statutory leave to track. Time off is a request, approved by a manager, with no balance and no accrual.

Teamtopia handles that setup with the Unpaid Leave (LWOP) type alone: allowance set to unlimited, approval on, calendar visibility on. The same shell later carries paid types if the company hires employees under local contracts.

There is a second, more useful pattern. A contractor's contract type decides what payroll does, and the office setting decides which leave rules the person lives under. A FOP contractor based in the US can be placed under the US office preset and get the same jury duty, voting, and safe leave rules as a colleague on a local contract. Teamtopia treats the office setting and the contract type as two separate decisions.

How do you set up leave rules per office in Teamtopia?

The flow has four steps.

1. Create the office and pick a region. USA, Europe (EU), or Ukraine. The region loads the default toggle states from the table above. In the USA preset, PTO is on and Annual Leave, Sick Leave, and Personal Days sit under it as sub-policies, off by default. In the Europe and Ukraine presets, PTO is off and the three separate types are on.

2. Switch leave types on or off for that office. A Lisbon office can enable School Activities Leave even though no Portuguese law requires it. A Kyiv office can turn on Sabbatical as a company benefit. A US office can enable Marriage Leave.

3. Open a type and adjust the policy. Every policy has the same core blocks: eligibility (minimum service), allowance (annual limit, consecutive days, notice), partial-day rules, payroll impact (paid, unpaid, or split), documentation, approval, effective date, and employee notifications. Leave-specific blocks appear where the type needs them: a payment split section for sick leave in Ukraine and much of the EU, a relationship matrix for bereavement, a privacy block for safe leave.

4. Set the effective date and notify the team. Policy changes are versioned. Employees get a summary by email or Slack, now or on the effective date, with an optional "I have read this" acknowledgment.

Two settings deserve a closer look because they connect unpaid leave to everything else.

Accrual on Unpaid Leave lives in the Annual Leave policy. It decides whether vacation days keep accumulating while someone is on unpaid leave. The Ukrainian default is off, which matches the seniority rule in the Law on Leave since December 2023. A company can turn it on as a benefit.

Regional Compliance Extras appear only for the selected region. For Ukraine that means a link to the mandatory vacation schedule (графік відпусток), a field for unused days from previous years that by law cannot expire, and a 14-day minimum consecutive block rule. For the US it means state selection on jury duty and a USERRA-aligned reinstatement window on military leave.

Which leave types are live, in development, and planned?

Live today (6 types): PTO, Sick Leave, Unpaid Leave (LWOP), Vacation Compensation, Overtime tracking, and Holiday Swap.

In development: the USA, Europe, and Ukraine presets; the next set of policy types (Bereavement Leave, Jury Duty, Parental Leave, Military Leave, Personal Leave, Voting Leave, Safe Leave, Blood/Organ Donation, Floating Holiday, Comp Time / Time in Lieu, Volunteer Time Off, No-show); and deep policy screens for Annual Leave, Sick Leave (with payment split), Maternity, Paternity, Parental, Carer's Leave, End-of-life Care, Religious Leave, Garden Leave, Sabbatical, Military, Jury Duty, and Bereavement with the relationship matrix, Pet Bereavement, and Miscarriage Leave toggles.

Planned: custom leave types. An office in a country with no law on pet illness will be able to create "Sick Pet" with its own days, proof rule, and calendar label, and an office anywhere will be able to define a type for a situation no preset covers.

How does Teamtopia compare with BambooHR, Personio, and HiBob?

All three competitors let you build custom time-off policies and assign them by location or group. The difference is where the legal knowledge sits.

	BambooHR	Personio	HiBob	Teamtopia
Custom policies by location or group	Yes	Yes	Yes	Yes
Country templates	No	Yes, guidance-level; built-in rules for Germany and the Netherlands	No	USA, Europe, Ukraine presets (in development)
Ukraine-specific rules (vacation schedule, 14-day block, military leave since 2022, Article 25/26 unpaid leave)	No	No	No	Yes
Leave-specific logic (sick pay split, bereavement relationship matrix, safe leave privacy)	Generic policy fields	Generic policy fields	Generic policy fields	Per-type sections
Pricing	Quote-based	Quote-based	Quote-based	$2 per user per month after a 3-month free trial

BambooHR's policy builder supports pausing accruals during long leave and prorating salary for unpaid time off through payroll. Personio ships country-specific absence templates but describes them as recommendations and warns against reusing a template from another country. HiBob's policy types mark each type as paid, unpaid, or working time and assign policies by site or department.

None of the three has a Ukraine-specific configuration. For a team with a Kyiv office, that means building the vacation schedule rule, the Article 25/26 distinction, and the post-2022 military leave rules by hand.

What should an unpaid leave policy include?

If you are writing the policy before configuring the tool, cover these points for each office:

1. Who can request it and after how many months of service.
2. Mandatory cases the law requires you to grant, listed by country.
3. Maximum length by agreement, and whether it can be split.
4. Notice period, with the statutory minimum where one exists (90 days in Portugal for study leave).
5. What happens to accruals: vacation days, seniority, health insurance, equipment.
6. Documentation: what proof is required, and when it can be submitted after the leave starts.
7. Approval chain: manager only, or manager plus HR or founder for long absences.
8. Return conditions: same position guaranteed, or comparable position.

Each of these maps to a field in the Teamtopia policy screen, so a written policy and the configured policy stay in sync.

Try it on your own offices. Teamtopia is free for three months, then $2 per user per month. Start a trial and set up your first office preset in under ten minutes.