Norway's progressive parental leave system encourages fathers to take more time off and aims to reduce gender inequality. But is it successful, or necessary?

In a few weeks' time the UK's paternity leave laws will change significantly. Under new additional paternity leave legislation, fathers of children born on or after 3 April 2011 will be able to share the maternity or adoption leave and pay if the mother or adopter returns to work early.

For now, this will be limited to a 26-week block of leave for fathers that can be taken between 20 weeks and one year after the child is born or placed for adoption. But don't expect the reforms to stop there: earlier in the year, deputy prime minister Nick Clegg announced the government's intention to further revolutionise Britain's "Edwardian" parental leave system, including proposals to let fathers step in for mothers six weeks after the birth, spread their leave in chunks, and a "lose it or use it" system whereby fathers could be offered a block of leave, possibly within the first 10 weeks.

Opponents – not least the small business lobby – have cried foul, arguing that such moves will engulf employers with red tape. Indeed there have been reports that businesses employing 10 or fewer people could yet be exempted from the legislation altogether.

But to understand how the system might work in practice look no further than the Nordic countries, which have been granting fathers generous parental leave for some time. It is all part of the region's cradle-to-grave welfare state model, providing family-friendly policies such as affordable public child daycare and lengthy paid leave, so more women can work yet still keep up the birth rate.

Arguably the trailblazer is Norway, which introduced shared parental leave in 1977 and was the first to establish a quota for fathers in 1993. Before that, only 2%-3% of Norwegian fathers took time off to be with their kids. Today, nine out of 10 fathers use the quota, currently 10 weeks but set to rise to 12 weeks later this year.

Norway's prime minister Jens Stoltenberg, along with justice minister Knut Storberget and family minister Audun Lysbakken – both coincidently currently on fathers' leave – have defended the use of "father quotas", which they say lay the basis for establishing good contact between father and child and give women better opportunities to participate in the workforce. They even want the quota to reach 14 weeks by 2013.

"When I took paternity leave, there were less than 400 [taking it]," Stoltenberg says. "Now, around 40,000 fathers take paternity leave."

But the system isn't always perfect. Many things need to fall into place: there has to be a willing employer that will allow the father to be away for so long; a robust enough family economy in case the employer doesn't cover the gap between the maximum salary level covered by the government (NOK465,000/£50,000) and the father's actual salary during the 10 weeks; and not least, a willing mother.

Espen Sandvik is one of the 18% of Norwegian fathers taking more than their quota. The 38-year-old corporate lawyer has been home in Oslo with his 13-month-old daughter, Synne, since November. He went back to his job as partner at Arntzen de Besche in March after 16 weeks of paternity leave – six weeks more than the current quota.

Sandvik chose to take a longer leave partly because his daughter was at the time without a daycare slot, and also because his partner, Hege Ugland, is expecting their second child later this month. She wanted to avoid being away too long from her job as a cellular biologist researcher at the University of Oslo – where she has already been off for 40 weeks – before she went back on maternity leave again earlier this month.

"I think it is good for me and for most men to be at home and to understand what it is like to take care of a child," Sandvik says.

He was also fortunate to be between assignments, having been outsourced as a corporate lawyer, and to have a generous employment contract that covers a "fair bit" of the pay gap between the maximum paternity pay and his fixed salary level during his leave.

This gap is not covered by law and varies from company to company. Most Norwegian firms have provisions for covering part of the gap, increasingly a more important benefit among employers competing for talent. But the practice varies widely among small- to medium-sized companies, some of which cannot afford the extra expense.

Anne Sødem, human resources director at Sweco's Norwegian unit in Oslo, admits her company struggled with the issue 10 years ago when she first started at the Swedish engineering and building consultancy. Only 14% of the labour pool at the time was female and she quickly learned her managers did not want to hire women because they got pregnant. As a result, she changed the rules so the company covered the difference between the covered maternity/paternity level and full salaries for both men and women. Since then the rate of female employment at the company has risen to 26%.

"As a consultancy we lose the income while they're away, but it is a long-term investment," Sødem says. "I could see that small companies would struggle with the liquidity, but mostly I see the upside for equality … the first time one of our male managers took off more than the required time, I wanted to go out and buy a cake."

The Norwegian government argues that there needs to be a quota for fathers, because otherwise they wouldn't bother taking the time off. It cites the dramatic drop in participation by fathers in Denmark after it removed its quota in 2002 as proof there needs to be a political solution. According to Norway's equality and anti-discrimination ombudsman, only 25% of Danish fathers now use their quota compared to 60% in Norway, putting the Danes bottom in the Nordic region.

Norway is proposing an even higher quota for fathers from this November, under a three-way split with 12 weeks for the father, 12 weeks for the mother, and 20 for "family negotiations". The total period of leave would be extended by a week to 47 weeks at 100% covered earnings up to the 6G level, three weeks of which are reserved for the mother before the birth, or 57 weeks at 80%.

By comparison, Iceland reserves three months each for fathers and mothers, and three months to be decided between them. Sweden offers 13 months at 80% covered earnings, which is split between the parents – two months of which are earmarked for each parent. Much like Norway, fathers in these countries make use of their paternity quota, and women take out the rest of the maternity leave, according to the Norwegian government. Swedish fathers on average take more than their quota.

Henriette Westhrin, Norway's deputy minister of children, equality and social inclusion, says one of the main ideas behind the proposed system is to provide a political solution for the differences in income between the sexes. The wage gap increases when women have children, and the more children they have, the more the difference becomes. In addition, there is a need for women to keep up the birth rate and still get back to work to help pay for the welfare costs associated with the country's ageing population.

"We think it makes for a more equal society," Westhrin says. "We see in Norway people get more children than most European countries and there are more women in the employment market. But we also have to make sure they are not just part-time jobs. We have to push women into work and have to pull men back into the family."

Norway's main employers' organisation, NHO, is positive about the proposed split, which it feels promotes more gender equality. Norway has a very gender-divided workforce with the majority of the private sector being male, while most women work in the public sector. By dividing the leave into three it wouldn't matter as much to employers whether they hire men or women, and it would encourage the latter to get back into the workforce, says Liv Raghnild Teig, an NHO departmental director.

"We like families to have children," Teig says. "We have close to two [children] per family – among the highest in Europe. But we also like them to join the workforce."

Still, the Norwegian system isn't perfect. Teig says they have seen that, in reality, men in high positions seldom take their leave because they cannot leave their jobs. Sunniva Ørstavik, Norway's equality and anti-discrimination ombudsman, complains that fathers cannot take out paternity leave if the mother hasn't earned the rights to maternity leave prior to birth, or goes back to work or school afterwards.

And, despite Nordic countries' family friendly and equal opportunity policies, there are critics who remain unconvinced that they have succeeded in eliminating sex differences in the labour market. Catherine Hakim, a senior research fellow at the London School of Economics, published a controversial study earlier this year entitled Feminist Myths and Magic Medicine. "The study [from 1970-1990] reveals that women are nurses while men are doctors; women are primary school teachers while men are university lecturers; women are secretaries while managers are men – and that these patterns are strongest in the Nordic countries," she claims.

It is doubtful that Norwegian prime minister Stoltenberg would agree with that verdict, despite Storberget and Lysbakken both being on paternity leave. "I miss them," Stoltenberg admitted recently, while calling in to see how the proud new dads were getting on. "But it can't be that men are more indispensable to the workplace – or to the government – than women."

Dads' army: changes to UK paternity leave

The present system New mothers can take up to 26 weeks of ordinary maternity leave and 26 weeks of additional leave, at 90% pay for the first six weeks, then up to £123.06 for the next 33 weeks, then unpaid thereafter (though some employers offer better terms). Fathers get two weeks' statutory paternity leave to be taken within 56 days of the birth, also paid at £123.06 a week, or 90% of your average weekly earnings, whichever is less (again, some employers offer better terms).

From 3 April Mothers will be able to transfer the second half of their 12-month entitlement to the father, up to a maximum of six months.

Proposed from 2015: Fathers to be entitled to step in after six weeks. Parents should be able to divide leave in chunks rather than be limited to lengthy stretches. Introduction of "use it or lose it" system in which fathers are offered a longer block of leave within, for example, 10 weeks of the birth.