On January 1st, a central promise made by the SPD during the last federal election campaign is fulfilled: Citizens’ allowance replaces Hartz IV. It is also worth taking a look abroad because there is such a heated argument about it in Germany. This is how other countries with the minimum income hold it.

The unemployment benefit II or Hartz IV introduced by red-green in 2005 as basic security will be history from next year. With the new citizens’ allowance, there will then be more financial support for the long-term unemployed with fewer sanction options.

Specifically, from January 1st, a standard rate of 502 instead of 449 euros per month will apply to single adults. Rental and heating costs are covered in full for the first two years. The savings increase to 60,000 euros. Above all, no sanctions should be imposed in the first six months if, for example, a job offer is rejected. As a result, if there is a lack of willingness to cooperate, the rate may only be reduced by a maximum of 30 percent.

The project met with a lack of understanding among the working population. The central point of criticism is that employees with low incomes are hardly better off than future recipients of citizen benefits.

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One thing is clear: the majority of the current 3.8 million Hartz IV recipients in Germany do not receive state aid for fun and money, but because otherwise it would no longer be enough to live on. Society’s support should go to them, who are often marked by fate. At the same time, unfortunately, there are also those who prefer not to work for personal reasons.

For example, a study by the German Institute for Economic Research (DIW) in cooperation with the Ruhr University Bochum, for which 560 long-term unemployed were interviewed in eight job centers, delivered surprising results in August. A whopping 41 percent “completely agreed” with the thesis that “there are many Hartz IV recipients who take advantage of the system”.

A look beyond national borders can certainly open up other perspectives here. However, since our neighbors do not have the combination of unemployment and social assistance that has been practiced in this country since 2005, the minimum income is used as a comparison. There are also major international differences in terms of the definition of poverty, the rules for access to basic security benefits, the calculation of standard rates, and also the obligations of recipients.

According to the European Parliament’s Directorate-General for Internal Policies of the Union, there are essentially four large blocs of countries:

A common European feature of minimum income schemes is that they provide benefits that are not linked to previous employment or contribution history. While first-tier support, unemployment assistance, usually requires contributions, safety-net benefits are means-tested.

Eligibility requirements in terms of wealth and income, residency or age vary significantly from country to country. Minimum income benefits in cash and in kind are permanent in many, but not all, countries.


There is no nationwide uniform social welfare law in Austria. Therefore, the standard rates differ depending on the federal state. In Vienna, for example, “those people who otherwise have no means of earning a living can obtain minimum income,” it says. Before social assistance or minimum security can be claimed, existing assets must be sold – up to a limit of 5867 euros. Exceptions here are the condominium used as the main residence and its furnishings. Anyone who owns a car must sell it – unless the vehicle is required for work or a disability.

Vienna’s minimum income consists of two parts: a maximum of EUR 733 to cover living expenses and EUR 244 to cover housing costs, totaling EUR 977 per month. People living together receive 1.5 times the amount. There are 264 euros each for children. Income, unemployment benefit, unemployment assistance, maintenance payments or pensions are taken into account and reduce the entitlement.

Persons able to work must always be willing to perform reasonable work. An offered job is considered reasonable if the physical ability of the unemployed person is taken into account and the work does not endanger health or morals. Up to two hours travel time for the outward and return journey is also considered reasonable for a full-time job. So strict requirements.

The temporary loss of unemployment benefit or unemployment assistance occurs when benefit recipients refuse to take up work. Even if you do not attend additional training or retraining, reject a measure to reintegrate into the labor market or show too little initiative to find a job, the entitlement can expire for six weeks, or eight weeks in the event of a recurrence.


In Italy, people in need have been able to apply for the “Reddito di cittadinanza” citizen income since 2019. It is granted for a maximum period of 18 months and can be reapplied after a one-month suspension. For single people who live for rent, the state benefit is up to 780 euros per month. For homeowners it is a maximum of 500 euros. Families with two underage children get a maximum of 1180 euros.

Not only the long-term unemployed can apply for this basic income, but also employed persons who earn less than 9360 euros a year. However, there are strict asset limits for this. If you own an expensive car, for example, you are not entitled to it. Even if a family member has resigned of their own accord in the past twelve months, the whole family is excluded from the civil income. There is no such regulation in Germany for the minimum income.


Something like Hartz IV also existed in the Netherlands. There it was called WWB or formulated Wet Werk en Bijstand (law for work and assistance) and roughly meant: first the work, then the help. The Participation Act (Pw), which has been in force since 2015, has not changed this principle of demanding and promoting. The basic principle of this Participation Act is that everyone takes part in social life to the best of their ability and earns their own living as far as possible.

The standard rates are linked to the statutory minimum wage. They are set for married people and life partners, single parents and people who live with several other people in one household. Single parents receive 1092 euros per month, a couple 1560 euros. There is no statutory maximum benefit period, but the municipality responsible for payment checks whether beneficiaries comply with certain clearly defined obligations. These need about

Those who fail to meet these strict obligations will have to cut support from the municipality. Single parents with full care of one or more children up to the age of five are exempt from the obligation to work.


The main purpose of social assistance in Poland is to help individuals and families to cope with difficult life situations. The aim is to restore a self-determined life and enable a life under dignified circumstances.

Social assistance benefits are not subject to contributions. In order to benefit from it, no proof of paid insurance premiums is required. They are available to people and families whose income does not exceed a certain threshold. Social assistance includes cash benefits and non-cash benefits in kind.


In France there is the Revenue de solidarité active (RSA). This solidarity allowance provides 565 euros per month for single people. A couple with two children receives 1186 euros. Reductions are possible, for example if other state benefits such as housing benefit are drawn. A reassessment takes place every three months. Assets such as home ownership, cars, and jewelry count. Only those who are willing to work receive the RSA.


Social Inclusion Income (Rendimento Social de Inserção, RSI) is available to individuals or families who are in serious financial need and need support to improve their social inclusion and who meet the eligibility requirements.

To be eligible for RSI, the value of the declared capital and movable property of the applicant and family members living in the household must not exceed EUR 26,145 each.

The maximum period for purchasing RSI of a maximum of 190 euros is twelve months. An extension can be requested as long as the conditions are met.

Switzerland (non-EU)

A single person who earns little or nothing receives 986 francs of social assistance per month in most Swiss cantons. That’s the equivalent of 1025 euros. This lump sum increases with the number of household members. The wealth allowance for individuals is 4,000 euros, for couples it is 8,000 euros and for children it is 2,000 euros.

Anyone who receives social assistance must provide truthful information about their income, assets, work and family circumstances. Above all, however, he or she must do everything possible to get back on his or her own two feet as quickly as possible. That also means: lying on the lazy skin is not. If you don’t try hard enough to find a new job and don’t send out any applications, you could face deductions of up to 30 percent.

Above all, however, the social assistance – unlike in Germany – has to be paid back. Depending on the canton, this obligation only expires five to 20 years after the last withdrawal.

Conclusion: Due to the different characteristics of their respective social systems as well as their purchasing power and cost of living, the individual countries cannot be compared 1:1. What is striking, however, is that the basic principle of promoting and challenging plays an important role in many European countries. The fact that Germany softens this basic principle, which has also applied in Germany to date, by making sanctions more difficult is at least remarkable.