However, legislation differs in France and Germany
In both countries, employees receive compensation for each unworked hour of between 60‑84% of their net hourly wage. This compensation may not, however, be less than the hourly minimum wage in France. The maximum length of compensation is now limited to 12 months in France, and up to a maximum of 1,607 hours per employee per year. In Germany, it can be extended by decree, depending on the economic situation of the country or of a particular sector.
There are three main differences in terms of legislation between France and Germany, which have become less pronounced since the Covid-19 crisis. First, short-time work includes non‑standard contracts such as fixed-term contracts and temporary workers in France, whereas in Germany it does not cover mini-jobs and temporary workers have only been taken into account as of April 2020. Second, in France, payments are made by firms, which are then reimbursed by the government and Unédic:-- up to EUR 7.23 per hour for firms with more than 250 employees and EUR 7.74 per hour for smaller firms. It should be noted that, since 17 March, this compensation has been fully covered. In Germany, compensation is fully funded by the public authorities, thus easing the financial constraints of companies. This difference seems to explain the greater take-up of short-time work in Germany in 2009. Third, in France, it is up to the administration to assess the level of difficulties, whereas in Germany the scheme includes thresholds for triggering the short-time work mechanism based on the proportion of employees and/or the number of hours concerned, which makes it possible to identify troubled firms more effectively. Businesses must also have exhausted all other options that could have allowed them to avoid using the short-time work mechanism. These conditions have been partially eased since the start of the Covid-19 crisis.
A widely adopted mechanism in a locked-down Europe
In Europe, short-time work is a flagship measure to combat the Covid-19 crisis. Many European countries have made reforms to this mechanism or have created such a scheme (Greece, Sweden). For instance, in Austria, Belgium, Ireland, the Netherlands, and the United Kingdom, this scheme is generally more generous towards employees and/or companies; in Austria, Spain and Finland, the procedure has been simplified; and, in Spain, the scope has been extended to benefit certain categories of previously excluded employees.
In order to encourage these initiatives, the European Commission announced on 2 April 2020 the creation of a financial assistance mechanism designed to protect the jobs threatened by the pandemic. Its proposed budget will be EUR 100 billion in the form of guarantees and soft loans to Member States in order to promote the creation or extension of national schemes such as short-time work.
However, while it protects jobs, the short-time work scheme may also have perverse effects, particularly if it is used for extended periods outside times of crisis. Some firms not experiencing difficulties may be tempted to take advantage of it to make a profit, putting a strain on public finances with a negative effect on hours worked without any gain in employment (windfall effect). Other firms, facing structural difficulties, would be tempted to use it, which delays or even prevents the reallocation of their labour force to more productive sectors. These negative effects result in a loss of aggregate output relative to the social optimum (Cahuc and Nevoux, 2018 ; Cooper et al., 2017). However, these effects remain relatively modest compared to the benefits of short-time work in times of crisis.