http://esp.sagepub.com
Journal of European Social Policy
2001; 11; 99Journal of European Social Policy
Sigrid Leitner
Sex and gender discrimination within EU pension systems
http://esp.sagepub.com/cgi/content/abstract/11/2/99
The online version of this article can be found at:
Published by:
http://www.sagepublications.com
can be found at:Journal of European Social PolicyAdditional services and information for
http://esp.sagepub.com/cgi/alertsEmail Alerts:
http://esp.sagepub.com/subscriptionsSubscriptions:
http://www.sagepub.com/journalsReprints.navReprints:
http://www.sagepub.com/journalsPermissions.navPermissions:
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
Summary
Drawing on the philosophical differentiation
between sex and gender, this article focuses on
structural mechanisms of gender discrimination
within European pension systems. For
this purpose, the article distinguishes between
two dimensions of the gender category: the
work behaviour dimension and the care
dimension. It is argued that the differentiation
between employment and family work on the
one hand and specific living arrangements on
the other is structurally implemented within
old age security systems. All countries have
established earnings-related schemes which, to
various extents, refer to former earnings and
continuous working careers. Many of the
earnings-related schemes incorporate family
work in one way or another by granting entitlement
for the care of children and/or elderly
or handicapped people. Most of the schemes
are combined with additional benefits for
spouses and/or survivors, referring to married
heterosexual couples. Only a few countries
have additionally established universal pension
schemes based on residence instead of
employment or family work. The comparative
analysis of pension systems in the 15 EU
member states gives an idea about national
varieties of structural gender differentiation.
Résumé
Partant de la différence philosophique entre
sexe et genre, cet article se centre sur les
mécanisme structurels de discrimination de
genre dans les systmes de pension européens.
Ľarticle distingue dans ce but entre deux
dimensions; la dimension du comportement de
travail et celle des soins (care). Nous argumentons
que la différentiation entre ďune part
ľemploi et le travail familial et les arrangements
spécifiques de vie de ľautre est mise en
oeuvre structurellement dans les systmes de
sécurité pour les personnes âgées. Tous les
pays ont établi des systme liés aux revenus
qui se réfrent aux niveaux de revenus
antérieurs et aux carrires professionnelles.
Nombreux sont les systmes qui,ďune façon
ou ďune autre, tiennent compte du travail
familial en accordant des droits pour la
période de soin des enfants et/ou de parents
âgés ou de personnes handicapées. La plupart
se combine avec des avantages supplémentaires
pour les épouses et/ou les personnes
survivantes en référence aux couples hétérosexuels
mariés. Seul quelques pays ont de
manire complémentaire établi des systmes
de pension universelle basés sur la résidence
plutôt que ľemploi ou le travail familial.
Ľanalyse comparative des systmes de
pension dans les 15 Etats membres de ľUE
fournit un aperçu des variétés nationales de
différence structurelle en termes de genre.
Introduction
During the last 20 years, various feminist
scholars have dealt with the discrimination of
Sex and gender discrimination within EU pension systems
Sigrid Leitner, University of Goettingen, Germany
ARTICLE
Key words
European Union, gender discrimination,
old age security, pension systems, sex
discrimination
Journal of European Social Policy 0958-9287 (200105)11:2 Copyright  2001 SAGE Publications, London, Thousand
Oaks and New Delhi, Vol 11 (2): 99­115; 017010
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
women within the welfare state. Apart from
the question of whether the welfare state
could be an instrument for women's emancipation
or if state-organized programmes are
an obstacle to women's liberation per se since
they reproduce patriarchal structures of
female subordination, there has been extensive
effort to push forward the agenda of gendering
welfare state research. One of the central
concerns of the debate was to uncover the
quantitative as well as the qualitative dimensions
of women's discrimination and to reveal
that all welfare states ­ though the degree of
discrimination varies enormously ­ systematically
treat women differently from men. On
the one hand, average benefit levels of women
are lower than those of men (e.g. Pearce,
1978; 1993; Schaffner Goldberg and Kremen,
1990), on the other hand, social security regulations
directly or indirectly reflect gendered
assumptions about social risk protection (e.g.
Sainsbury, 1994; 1999). This structural gender
bias of welfare states has by now also been
acknowledged within mainstream discussions
(e.g. Esping-Andersen, 1996). Nevertheless,
the gender dimension is not usually considered
as a central category of welfare state research.
This paper, in contrast, contributes to the gendering
of welfare states and focuses on the
systematic analysis of sex and gender discrimination
within social security.
Feminist research has been able to identify
distinct mechanisms of gender discrimination
within welfare states. Barbara Nelson (1990)
was the first to show for the United States that
the existence of a `two-channel welfare state'
leads to a gender-specific segmentation of
benefit recipients. Men are over-represented
within social security programmes which
grant relatively generous entitlements on the
basis of social rights earned by contribution
payments. Women, however, are over-represented
within means-tested welfare programmes
which provide less generous benefits
and grant entitlements on the basis of need
and social stigma. Linda Gordon (1994) sheds
light on the history of restrictive and punitive
welfare policies for single mothers and Theda
Skocpol (1995) demonstrated that programmes
targeted at men (soldiers/veterans)
traditionally provide higher benefits and carry
with them less social stigma than programmes
targeted at women (mothers).
In continental Europe, the feminist debate
has focused on two main topics: the earningsrelated
structure of social security systems,
together with the traditional division of
labour between the sexes, has been identified
as the main cause of women's discrimination
within these systems. In addition, the privileged
treatment of traditional family arrangements,
incorporated by the double deal of
subsidiarity on the one hand and entitlements
for spouses on the other, has been viewed as
responsible for maintaining the sexual division
of labour (early works: Kickbusch and
Riedmüller, 1984; Gerhard et al., 1988). The
principle of subsidiarity requires a specific
organization of work within the private
household: while one person functions as
family breadwinner, the other person cares for
the family. Only in case of family malfunction
does the welfare state step in to substitute
either the breadwinner or the family carer. As
a consequence, in earnings-related social security
schemes the (mostly male) breadwinner is
directly entitled to social protection whereas
the (predominantly female) family carer
derives entitlement only indirectly from her
(his) relationship to a breadwinner, a fact
which mirrors dependency structures within
the family. By granting indirectly-derived benefits
to the family worker as well as by limiting
the supply of public social services to a
minimum, the welfare state helps maintain the
traditional division of labour (Langan and
Ostner, 1991).
Yet another form of gender-specific relation
to the welfare state has been discussed by
Scandinavian feminists who detected that
women's dependence on the welfare state has
an extra dimension. The expansion of the
public-service sector led to a significant
increase in the number of women employed
by the state, thereby shifting women's patriarchal
dependence from the husband to the state
100 LEITNER
Journal of European Social Policy 2001 11 (2)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
(early works: Holter, 1984; Hernes, 1989).
Whereas, traditionally, care work was done by
women in the private household, reinforcing
their financial dependence on the husband, the
Nordic welfare states have made care work
public work paid for by the state1 and thereby
transforming the quality of women's dependence
while at the same time maintaining their
dependence on a patriarchal institution.
The following analysis mainly stems from
feminist research on earnings-related benefit
provision as well as on the privileged treatment
of traditional family arrangements. It
tries to combine and reconceptualize existing
findings on the discrimination of women
within social security. For this purpose, I draw
from the philosophical differentiation between
gender and sex and its application for social
policy analysis (Leitner, 1999a; 1999b). I will
mainly focus on the gender category which
includes two analytical dimensions: the work
behaviour dimension and the care dimension.
I will argue that the differentiation between
`male' and `female' work behaviour as well as
between morally `righť and `wrong' care
arrangements is structurally implemented
within social policy. These structural mechanisms
of gender differentiation also work
within old age security systems ­ though to
different degrees. A comparative analysis of
pension systems in the European Union will
give an idea about national varieties of structural
gender differentiation.
How to conceptualize sex and gender
differences within social security?
Recent developments in feminist theory urge
for a more sensitive use of the central analytical
category `woman'. Afro-American feminists
like bell hooks (1984) were the first to
raise our consciousness about the differences
among women, so when we speak about
women we have to keep in mind the broad
range of female realities. This concept of
differences has forcefully been pushed by
constructivist theorists like Judith Butler
(1990; 1993). Since every individual is a
complex and unique human being, we have to
leave behind the old bipolar categories of
`women' and `men'. These categories are oversimplified
concepts which should be replaced
by multidimensional thinking. Being a
(wo)man has been split into two dimensions:
gender, the ascribed social role of (wo)men;
and sex, the categorization of humans on the
basis of biological characteristics.
The biological dimension
The biological differentiation uses biologically
determined differences to legitimize different
treatment of men and women. This kind of
sex differentiation is institutionalized within
social policy by implementing regulations that
refer explicitly to biological sex differences.
With regard to pension systems, two types of
biological differentiation can be observed
across Europe: (a) unequal pension age regulations
for men and women and (b) unequal
access to survivor pension entitlements for
men and women. Both forms of different
treatment usually benefit women: traditionally,
in many European countries, their
pension age has been (is) lower than that of
men, and men have been denied access to survivor
pensions. Be it that these differentiations
were implemented for actuarial reasons or as
a result of cultural attributions of gender
roles,2 sex discrimination results from connecting
biological and work behaviour differentiation:
all men following `female' work
behaviour are not compensated at all, while
women following `male' work behaviour are
recompensed as if they were on `female' work
behaviour. It is this kind of sex discrimination
that has been challenged by EU law. As a
consequence, most countries equalized the
pension age of men and women (see Table 1) mostly
by increasing women's pension age,
which points to the fact that these reforms
have also been driven by the effort to lower
the cost of national pension schemes. Article
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 101
Journal of European Social Policy 2001 11 (2)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
119 of the EU Treaty is definitely a hindrance
to unequal survivor benefit entitlements which
caused a belated installation of widowers'
pensions in most of the member states.
It can be summarized that discrimination
due to biological differentiation is diminishing
within European pension schemes. In the following
section, I will focus on the gender category
and distinguish between work behaviour
differentiation/discrimination and differentiation/discrimination
due to care arrangements.
The work behaviour dimension
Work behaviour differentiation results from
the distinction between a public sphere of paid
employment and a private sphere of unpaid
family work. Structural mechanisms of work
behaviour differentiation are implemented
within social policy by distinctive schemes for
employment and family work respectively.
The differentiation is non-discriminatory if
both kinds of schemes provide equal protection
with regard to benefit levels and the
quality of social rights. However, the empirical
reality of social policy shows discriminatory
characteristics: relatively generous social
security schemes operate for employment,
whereas family work is insufficiently, or not at
all, protected. The structure of a two-channel
welfare state with an earnings-related and a
means-tested system of benefit provision
represents very clearly this kind of gender
discrimination: continuous employment in
combination with full contribution payments
leads to high-level security whereas those in
discontinuous employment, part-time employment,
and unpaid work are worse off (Lewis,
1992).
Feminist social policy analyses should be
aware that discrimination against family work
does not automatically induce a discrimination
of `women'. This conclusion can only be
drawn in a second analytical step which identifies
society's current division of labour
between the sexes. If the discrimination of
family work corresponds to a traditional
sexual division of labour within the welfare
state's population, we can speak of an indirectly
derived discrimination of women keeping
in mind that (a) men doing family
work are also affected by structural work
behaviour discrimination and that (b) employed
men and women without family responsibilities
benefit from this discrimination.
The care dimension
The care dimension presumes that individuals
relate to one another. These interdependencies
take as many different forms of interpersonal
relationships and personal living arrangements
as there are: e.g. heterosexual and
homosexual partnerships, married and
unmarried couples, parent and child relationships,
and so on. Discriminating effects result
from the privileged treatment of a special kind
of reciprocal living arrangement. Thus in
general, heterosexual couples ­ and especially
those in the traditional form of marriage are
supported by social politics; homosexual
partnerships ­ and in most cases also non-
102 LEITNER
Journal of European Social Policy 2001 11 (2)
Table 1 Pension-age regulations for men and women in the EU
A B DK SF F D GR IR I L NL P E S UK
Men 65 65 67 65 60 65 65 65 65 65 65 65 65 65 65
Women 60a 62b 67 65 60 65 60c 65 60 65 65 65 65 65 60
Notes:
a Will be increased to 65 until 2033.
b Will be increased to 65 until 2009.
c Has been increased to 65 for those insured from 1.1.1993.
Source: BMA (1999).
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
married heterosexual partnerships ­ are not
equally protected. Social security systems which
do not refer to individuals but to a special
kind of care relationship discriminate on the
basis of alternative living arrangements.
The `male-breadwinner-marriage' represents
a special example of gender discrimination.
This concept combines care and work behaviour
differentiation in a unique manner by
referring to a heterosexual married couple
that follows the traditional sexual division of
labour. Idealizing this traditional family
arrangement within social policy also means
reproducing personal relationships of power
and dependence among family members ­ the
more so if done in combination with earningsrelated
benefit provision: the husband is
employed (full time) and acquires social security
entitlements for himself and his dependants,
whereas the wife is the family worker
and receives social protection only indirectly
through her husband.
Old age security schemes refer to different
extents to these mechanisms of gender discrimination.
All countries established earnings-related
schemes, most of them in
combination with additional benefit schemes
for spouses and/or survivors which refer to
married heterosexual couples. Most of the
earnings-related schemes incorporate family
work in one way or the other by granting entitlements
for the care of children and/or elderly
or disabled people. In addition, some countries
have established universal pension
schemes based on residence while others
provide minimum income schemes for the
elderly based on need. In the following
section, the broad range of old age security
schemes in the 15 EU-member countries will
be analysed to identify variations of gender
discrimination across Western Europe.
Mechanisms of gender discrimination
within old age security schemes
Apart from the Netherlands, all of the
countries compared established obligatory
state-organized employment-related pension
schemes, which means institutionalizing work
behaviour differentiation within old age security
systems.3 Work behaviour discrimination
plays an important role within employmentrelated
pension schemes since they are mostly
based on the norm of continuous full-time
employment.
Work behaviour discrimination within
state-organized earnings-related schemes
First, access to earnings-related pension entitlements
is restricted by specific qualifying
conditions (see Table 2). Denmark, for
example, excludes people employed for less
than nine hours per week, unless they work
for more than one employer. Finland denies
access to the scheme if the working contract
lasts for less than one month, and in Sweden
as well as in the United Kingdom (SERPS) low
income earners do not have access to the earnings-related
scheme. In all countries except
Belgium and Denmark a minimum duration of
insurance coverage is required to acquire eligibility.
Whereas this minimum qualifying
period can be as low as three months in
France, one year in Finland or three years in
Ireland and Sweden, four countries (Austria,
Greece, Portugal and Spain) require at least 15
years of coverage.
The establishment of minimum qualifying
conditions reduces the number of employed
persons entitled to pension rights by excluding
those working discontinuously and/or those
on low incomes, which are two characteristics
of women's labour-market participation across
Europe (Luckhaus and Ward, 1996). Those
who are entitled are again split into different
groups according to the duration of coverage
and the level of income when it comes to
benefit calculation, since pension formulae
reflect the amount of average earnings as well
as the length of coverage (see Tables 2 and 3).
Some schemes base the earnings-related
pension benefit on a percentage of average
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 103
Journal of European Social Policy 2001 11 (2)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
earnings during a determined period of the
individuaľs working life (e.g. two of the last
four years in Finland, the last five years in
Greece, the 10 best years in Portugal, the 15
best years in Austria, the last 15 years in
Spain, the 17 best years in France, the 20 best
years in the United Kingdom [SERPS]). Other
schemes (e.g. Belgium, Germany, Italy,
Sweden) refer to average lifetime earnings or
lifetime contributions for benefit calculation,
while others still grant employment-related
benefits without taking into account individual
earnings (e.g. Denmark,4 Ireland, the
United Kingdom [Basic Pension]). Finally,
Luxembourg grants a lump-sum benefit calculated
independently of previous earnings, but
related to years of contribution, whereas lifetime
earnings are considered for benefit calculation.
The longer the period on which benefit
calculations are based, the smaller the benefit
base in general. Long calculation periods privilege
continuously high-earning labour market
careers which can be found more often among
men than among women.
For calculating the final benefit, the benefit
base is usually related to the number of coverage
years. Some countries limit the maximum
number of years taken into consideration (e.g.
35 years in Greece and Spain, 37.5 years in
France, 40 years in Denmark, Finland,
104 LEITNER
Journal of European Social Policy 2001 11 (2)
Table 2 Qualifying conditions and maximum number of years considered within state earningsrelated
schemes
Qualifying conditions Maximum number of coverage years
Austria 15 years of contributions 45 years
(or 25 years of coverage)
Belgium None 45 years (men), 42 years (women; will be 45
years from 2009)
Denmark Employment of at least 9 hours 40 years
per week or at more than one
employer per week
Finland 1 year of coverage, access only 40 years
if working contract lasts for at
least one month
France 1 quarter of coverage 37.5 years (will be 40 years from 2003)
Germany 5 years of coverage No limit
Greece 15 years of coverage 35 years
Ireland 156 weeks of paid contributions Continuous contributions/coverage required
Italy 5 years of contributions No limit
Luxembourg 120 months of coverage 40 years
Portugal 15 years of contributions 40 years
Spain 15 years of contributions 35 years
Sweden 3 years of coverage, exclusion No limit
of low-income earners
United Kingdom 1 year of contributions plus 90% of working life between 16th and 65th
coverage for 25% of the working (men) or 60th (women) year (Basic Pension);
life (Basic Pension). Only income no limit (SERPS)
above the base amount is counted
for SERPS.
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
Luxembourg and Portugal, 45 years in Austria
and Belgium); other countries do not set any
limitation (e.g. Germany, Italy, Sweden and
the United Kingdom [SERPS]) or require continuous
coverage over most of the individuaľs
working life (Ireland, the United Kingdom
[Basic Pension]). The higher the number of
years considered, the more a scheme privileges
continuous employment careers.
Thus, work behaviour discrimination
within earnings-related pension schemes is
caused by minimum qualifying conditions
which restrict the access to pension schemes;
by considering rather long periods of bestearning
years for calculating the benefit base;
and by referring to long periods of insurance
coverage for the final benefit calculations.5
Earnings-related schemes may also grant
additional credits for unpaid care work which
marks a break in their basic organizational
logic. Most of the schemes compared consider
periods of caring for young children in benefit
calculation (see Table 4); only Denmark,
Finland, and the United Kingdom (SERPS) do
not. The length of the periods credited ranges
from a maximum of six months in Greece and
Italy, one year in Spain, two years in Belgium,
France, Luxembourg and Portugal, three years
in Germany, four years in Austria and
Sweden, up to 16 years in Ireland and the
United Kingdom (Basic Pension).
Only seven of the schemes consider periods
of care for close family members (see Table 4).
Whereas Austria offers a subsidized optional
insurance for family carers, Finland, Germany,
Italy, Ireland, Sweden and the United
Kingdom (Basic Pension) grant different kinds
of pension rights for family care. It is interesting
to note that Italy also has a voluntary but
subsidized pension scheme for housewives.
Though benefits provided on the basis of
caring periods are generally low compared to
benefits on the basis of earnings, it has to be
acknowledged that including care work within
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 105
Journal of European Social Policy 2001 11 (2)
Table 3 Calculation of the benefit base within state earnings-related schemes
Austria Average earnings during the best 15 years
Belgium Average lifetime earnings
Denmark Employment-related benefit (according to number of hours employed)
Finland Average earnings during 2 years of the last 4 years by eliminating the highest and the
lowest earning year (raised to average earnings during the last 10 years until 2005)
France Average earnings during the 17 best years (raised to 25 best years until 2008)
Germany Total of individual annual earning points (individuaľs annual earnings divided by
the annual average earnings of all contributors)
Greece Average earnings during the last 5 years
Ireland Employment-related benefit (according to average amount of contribution weeks per
year)
Italy Accumulated lifetime contributions
Luxembourg Lump-sum benefit (according to number of contribution years) plus average lifetime
earnings
Portugal Average earnings during the best 10 of the last 15 years
Spain Average earnings during the last 15 years
Sweden Lifetime contributions
United Kingdom Employment-related benefit (according to duration of coverage) (Basic Pension) plus
average surplus earnings during the whole working life (SERPS)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
earnings-related schemes is increasingly
becoming an issue in pension policy (Daly,
1997; Lewis, 1998). Crediting care work is an
attempt to mitigate mechanisms of work
behaviour discrimination within old age security.
Although earnings-related norms are not
being fundamentally revised, they are nevertheless
supplemented by regulations which
aim at allowing for a combination of employment
and family work. This can be interpreted
as a positive first step towards equal treatment
of different work behaviour, but it has to be
106 LEITNER
Journal of European Social Policy 2001 11 (2)
Table 4 Credits for child care and family care within state earnings-related schemes
Credits for child care Credits for family care
Austria 4 years of coverage for each child Subsidized optional insurance for carers
(maximum), benefit based on a fixed
amount
Belgium 2 years of coverage (maximum) None
Denmark None None
Finland None Pension rights for carers who receive a
home-care allowance
France 2 years of coverage for each child (for None
mothers only), plus: pension is increased
by 10% if the insured has reared at least
3 children
Germany 3 years of coverage for each child, benefit Coverage of informal carers, benefit
based on annual average earnings of all based on 27­80% of annual average
contributors (child care credits will be earnings of all contributors (depends on
extended by the 2001 reforms) weekly amount of care provided)
Greece 3­6 months of coverage per child (for None
mothers only)
Ireland The number of years spent caring for The number of years spent caring for
children under 16 years of age is elderly, ill or incapacitated persons is
disregarded for the purpose of disregarded for the purpose of calculating
calculating the number of qualifying the number of qualifying years for a full
years for a full pension pension
Italy 6 months of coverage for each child 1 month of coverage per year for carers
(maximum, only for mothers); employed (maximum)
mothers can alternatively reduce their
pension age by 4 months per child
(maximum of 12 months)
Luxembourg 2 years of coverage for each child None
Portugal 2 years of coverage for each child None
Spain 1 year of coverage for each child None
Sweden 4 years of coverage for each child Coverage for care of an ill or disabled
child under age 16
United Kingdom Periods spent caring for children under Periods spent caring for elderly, ill or
age 16 are credited within the Basic incapacitated persons are credited within
Pension system if at least 20 contribution the Basic Pension system if at least 20
years exist contribution years exist
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 107
Journal of European Social Policy 2001 11 (2)
clearly stated that in most countries credits for
care are not based on amounts that equal entitlements
gained from employment, thereby
maintaining gender discrimination though to a
lesser degree than before: `Although credits
offer important compensation for time spent
undertaking caring work, in the present policy
and labour market context such compensation
is partial and the crediting system therefore
remains a flawed instrument for addressing
gender inequality' (Rake, 1999: 234). In most
countries, benefits for care are available for
both sexes. But still much more often than
men, women do the unpaid caring work
making the unequal treatment of care predominantly
an issue of the indirect discrimination
of women within old age security.
Care discrimination within stateorganized
pension schemes
Apart from crediting care work within earnings-related
schemes, most of the countries
compared provide old age benefits for unpaid
care work together with state-organized earnings-related
benefits in the form of spouse
and/or survivor benefits (see Table 5). Contrary
to entitlement regulations in earningsrelated
schemes, it is not the individuaľs
caring career that qualifies for entitlement (as
would be the individuaľs employment career
in the earnings-related schemes), but the
family worker's status of being married to a
person who is covered by the earnings-related
scheme. This indicates a different quality of
Table 5 Old age benefits for spouses and survivors in the EU
Austria Survivor: 40­60% of the deceaseďs pension (income-tested)
Belgium Spouse: Additional 15% of the insureďs average lifetime earnings
Survivor: 80% of the couple's pension (income-tested)
Denmark Survivor: Monetary compensation (income-tested)
Finland Survivor: Percentage of the earnings-related pension of the deceased (income-tested)
France Spouse: Additional flat-rate supplement (income-tested)
Survivor: 54% of the deceaseďs pension (income-tested)
Germany Survivor: 60% of the deceaseďs pension (income-tested) (will be reduced to 55% by
the 2001 reforms)
Greece Spouse: Flat-rate supplement for dependent spouse
Survivor: 70% (50% for future generations) of the deceaseďs pension
Ireland Spouse: Flat-rate supplement
Survivor: Basic pension of the deceased. If the survivor receives a basic pension on
her/his own, the higher of the benefits is provided
Italy Survivor: 60% of the deceaseďs pension (income-tested)
Luxembourg Survivor: 100% of the deceaseďs lump-sum benefit plus 75% of the deceaseďs
earnings-related additional benefit (income-tested)
Portugal Survivor: 60% of the deceaseďs pension
Spain Survivor: 45% of the deceaseďs pension
Sweden Survivor: 40% of the deceaseďs pension, restricted to 12 months after his/her death
United Kingdom Spouse: Flat-rate benefit together with the Basic Pension; spouses with a Basic
Pension on their own can top it up to 60% of the partner's Basic Pension
Survivor: Basic Pension of the deceased plus 50% of the deceaseďs earnings-related
pension from SERPS
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
108 LEITNER
Journal of European Social Policy 2001 11 (2)
entitlement for family work since entitlement
does not result from direct but indirect social
rights.
Additional benefits for spouses of persons
who are entitled to a state earnings-related
pension are granted in Belgium, France,
Greece, Ireland and the United Kingdom
(Basic Pension). Old age benefits for survivors
of persons who were entitled to an earningsrelated
pension exist in all EU-member states.
Usually, the survivor benefit amounts to a percentage
of the deceaseďs pension benefit. The
exceptions here are Denmark, where the survivor's
pension was substituted by a monetary
compensation in 1992, and Sweden, where
survivor pensions are restricted to a 12-month
period. Those benefits targeting married family
workers reflect the norm of heterosexuality
combined with the institution of marriage,
thus discriminating on the basis of alternative
sexual orientation and alternative forms of
living together.
Moreover, spouse and survivor benefits subsidize
and therefore maintain family arrangements
which are based on the (traditional)
division of labour between the sexes. In most
countries, benefits are granted regardless of
whether the family worker has been fulfilling
her (his) obligations or not, since marriage is
taken as sufficient indication of how labour is
divided within the private household, namely
along traditional lines. This is even explicitly
formulated in some countries, for example in
Greece, where widowers are only entitled to
survivor benefits in case of invalidity and
material dependence on the deceased wife.
Some countries require an income test to
determine benefit provision for spouses and
survivors, thus controlling to a certain extent
whether the (traditional) division of labour
between the sexes has been in place.
Hence, old age benefits for unpaid care
work are provided in two distinct ways. On
the one hand, credit for care may be granted
within the employment-related scheme which
has the advantage of disregarding the carer's
(reciprocal) living arrangement and the disadvantage
of worse benefit quality compared to
earnings-related benefit calculation. On the
other hand, benefits may be granted to
married (heterosexual) family workers together
with earnings-related schemes, which indicates
care discrimination but also work behaviour
discrimination since benefits are generally
lower than the earnings-related pension benefit
of the family breadwinner and entitlements
are indirectly derived. Two statements summarize
this part of the analysis: first, unpaid
care work results in lower quality benefits;
and second, unpaid care work within marriage
is better off than that outside marriage.
Universal and means-tested schemes
Only a few countries have established universal
pension schemes which provide individualized
benefits regardless of care arrangements.
Moreover, universal pension benefits are
based on the duration of residence, thus
neglecting work behaviour differentiation.
Such schemes can be found in Denmark,
Finland, the Netherlands and Sweden (see
Table 6). It has to be noted that only in the
Netherlands is no income-test required for
benefit entitlement.
The other European countries ­ with the
exceptions of Austria and Germany ­ offer
means-tested minimum income provisions for
the elderly which constitute a last resort for all
those not sufficiently protected by earningsrelated
and/or family worker benefits. Meanstested
benefits do not per se lead to gender
discrimination. Nevertheless, it can be argued
that the clientele of such benefits is probably
restricted to people who failed in the labour
market or who were long-term family
workers. Thus, means-tested benefits reproduce
work behaviour discrimination, since
they are typically of very low quality.
A comparative interpretation
What conclusions can be drawn from this
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
structural analysis of gender discrimination
within old age security systems in the
European Union? How do work behaviour
and care discrimination vary across Europe?
The analysis given allows a classification of
the compared pension schemes according to
their degree of gender discrimination. Therefore,
categories of low, medium and high
work behaviour discrimination have been
defined and the schemes were attributed
accordingly (see Table 7).
The category `Access' reflects the minimum
period of coverage required by a pension
scheme to reach eligibility for pension entitlement.
The 15 schemes under consideration fall
clearly into three groups: those with high
requirements of 15 years of coverage; those
with low-level conditions of up to five years of
coverage; and those in between the two
groups (compare Table 2). Under the heading
`Benefit base', the schemes are classified
according to the length of the period during
which income averages ­ which build the base
for benefit calculation ­ are considered.
Again, two contrasting poles can be distinguished:
one group of schemes bases benefit
calculations on average lifetime income, which
represents a high degree of work behaviour
discrimination, whereas another group of
schemes is hardly discriminating in this
regard. The remaining schemes show time
periods between 10 and 17 years. Luxembourg
is the only critical case as it combines
lifetime earnings with a lump-sum benefit
which does not refer to former income at all.
This mixture of highly and less discriminating
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 109
Journal of European Social Policy 2001 11 (2)
Table 6 Old age benefits based on residence and/or need in EU
Austria General welfare
Belgium Means-tested flat-rate benefit
Denmark Full pension requires 40 years of residence (minimum: 3 years)
Flat-rate benefit varies with the duration of residence, 1/40 of full rate for each year
of residence. Benefit is reduced in case of high income
Finland Full pension requires 40 years of residence (minimum: 3 years)
Means-tested flat-rate benefit varies with the duration of residence, 1/40 of full rate
for each year of residence
France Means-tested allowance up to a basic minimum
Germany General welfare
Greece Means-tested flat-rate benefit
Ireland Means-tested flat-rate benefit
Italy Means-tested minimum income
Luxembourg Means-tested minimum income if 10 years of residence during the last 20 years
Netherlands Full pension requires 50 years of residence
Flat-rate benefit varies with the duration of residence, 2% of full flat-rate for each
year of residence
Portugal Means-tested flat-rate benefit
Spain Means-tested flat-rate benefit if 10 years of residence
Sweden Full pension requires 40 years of residence (minimum: 3 years)
Income-tested flat-rate benefit varies with the duration of residence, 1/40 of full rate
for each year of residence
United Kingdom Means-tested flat-rate benefit if 10 years of residence during the last 20 years
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
elements in the Luxembourg pension scheme
places it in the middle group (compare Table
3). The category `Number of years' indicates
the degree to which a certain scheme privileges
long periods of insurance coverage. Low
discrimination is proffered by schemes which
restrict benefit calculations to a maximum of
35­40 coverage years. This allows for insurance
spells of a minimum of 10­15 years. The
medium cluster comprises schemes which consider
a maximum of 45 years of coverage.
Finally, the highest degree of discrimination is
found in schemes which consider the entire
working life. The Irish pension scheme was
added to this group because it requires continuous
contribution payments over the whole
insurance period. Yet it has to be noted that
the Irish scheme does not require coverage
over the whole working life (compare Table
2). The classification scheme further tries to
capture the degree to which care work is recognized
by the state earnings-related pension
schemes. The category `Child care' distinguishes
between highly discriminating
schemes which do not or hardly consider
periods of child care for benefit calculation;
between schemes which consider child care to
a noticeable degree; and finally, schemes with
extensive consideration of child-care periods
(compare Table 4). Similarly, the category
`Family care' comprises a highly discriminating
group of schemes which do not consider
periods spent caring for family members at all.
These are followed by schemes which consider
family care to a minimal degree and others
which have developed more comprehensive
structures recognizing family-care periods for
pension purposes (compare Table 4).
In addition, for the following analysis, care
discrimination (which is the other dimension
110 LEITNER
Journal of European Social Policy 2001 11 (2)
Table 7 Classification scheme concerning the degree of work behaviour discrimination
(high­medium­low) within state earnings-related pension schemes
Low discrimination Medium discrimination High discrimination
Access Minimum qualifying Minimum qualifying Minimum qualifying
condition of up to 5 years: condition of more than condition of 15 years:
B, DK, SF, F, D, IR, I, S, 5 but less than 15 years: A, GR, P, E
UK (SERPS) L, UK (Basic Pension)
Benefit base Consideration of average Consideration of average Consideration of average
earnings during at most earnings during at least lifetime earnings:
5 years: 10 and at most 17 years: B, D, I, S, UK (SERPS)
DK, SF, GR, IR, UK A, F, (L), P, E
(Basic Pension)
Number of years Benefit calculation Benefit calculation Benefit calculation
considers a maximum of considers a maximum of considers more than
35 to 40 contribution 45 years of contribution 45 years:
years: or coverage: D, I, (IR), S, UK (SERPS)
DK, SF, F, GR, L, P, E A, B, UK (Basic Pension)
Child care Schemes which consider Schemes which consider Schemes which do not or
up to 16 years of child between 2 and 4 years of hardly consider child
care: child care: care:
IR, UK (Basic Pension) A, B, F, D, L, P, S DK, SF, GR, I, E, UK
(SERPS)
Family care Schemes which consider Schemes which consider Schemes which do not
family care to a family care to a minimal consider family care:
remarkable degree: degree: B, DK, F, GR, L, P, E, UK
SF, D, IR, S, UK (Basic A, I (SERPS)
Pension)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 111
Journal of European Social Policy 2001 11 (2)
of gender discrimination) is transformed into
a dichotomous variable. In this sense, care
discrimination takes place when a pension
scheme comprises survivor and/or spouse benefits
(compare Table 5).
For the comparative interpretation which
aims at grouping pension schemes according
to their structural profile of gender discrimination,
I will, in a first step, follow the wellknown
categories of Beveridge-type systems
and Bismarck-type systems. There are six
European countries with Beveridge-type
pension systems. They combine universal or
basic pension schemes with earnings-related
supplementary schemes.6 Comparing their
universal schemes (see Table 8), we see, as a
first homogeneous group, the Netherlands
together with the three Scandinavian countries.
Their universal schemes are non-discriminatory
in both the work behaviour and the
care dimension since they refer to residence
instead of work as well as to individuals
instead of family status. The principle of universality
`fundamentally focuses on the individual
legal claim [...]. If this principle were to
be fully implemented, complete gender neutrality
concerning coverage would exist in
such an old-age security scheme' (Döring et
al., 1994: 3). Following this analysis, a second
group of `universaľ pension schemes is
formed by Ireland and the United Kingdom.
Their basic pension schemes are based on
employment instead of residence, but work
behaviour discrimination within the basic
pension schemes is low since they do not refer
to former earnings and since care work is generously
credited within the scheme. In contrast
to the first group of universal schemes, family
work is taken as a basis for benefits paid to
spouses and survivors which indicates care
discrimination and, therefore, contradicts the
principle of universality. Hence, a first cluster
of six (quasi) universal pension schemes can
be identified which ­ besides the contradictions
named above ­ signal a high degree of
gender neutrality.7
In a second step, the state earnings-related
schemes of the Beveridge-type pension systems
are analysed alongside the Bismarck-type pension
systems. In contrast to universal schemes,
entitlements in earnings-related schemes are
earned instead of granted. `In the process of
drawing boundaries around how pension entitlements
can be earned, certain forms of work
are validated over others' (Rake, 1999: 224).
Usually employment generates entitlements,
Table 8 Work behaviour and care discrimination in universal pension schemes
Work behaviour discrimination Care discrimination
Benefit Number Spouse Survivor
Access base of years Child care Family care benefit benefit
Denmark
Universal Scheme Residence-based Individualized
Finland
Universal Scheme Residence-based Individualized
Netherlands
Universal Scheme Residence-based Individualized
Sweden
Universal Scheme Residence-based Individualized
Ireland
Basic Pension Low Low High Low Low Yes Yes
United Kingdom
Basic Pension Medium Low Medium Low Low Yes Yes
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
whereas care work does not or if it does then
at a considerably lower level. But entitlements
earned due to employment (contribution payments)
differ according to income levels
(amount of contribution payments) and continuity
of employment (duration of contribution
payments). The stronger the link to
lifetime-earnings and the higher the number of
years taken into consideration for benefit calculation,
the more severely care work is penalized
by the scheme. Following this causal
argument, at least three groups of earningsrelated
pension schemes can be distinguished
(see Table 9). First, we see the Danish and the
Finnish schemes, both of which are low discriminatory,
though not universal, as access is
restricted to the employed, and not quasi-universal
since care work is not (DK) or only
partly (SF) credited. For those with access to
the schemes, this lack of recognition of care
work is counterbalanced by the relatively
small number of years necessary to be considered
for benefit calculation.
A second group is made up by the Belgian,
German, Italian, Swedish (ATP), and British
(SERPS) earnings-related schemes. All of these
are rather easily accessible but link benefits to
average lifetime earnings. Moreover, they consider
­ with the exception of the Belgian
scheme ­ more than 45 years of coverage for
benefit calculation. This highly discriminatory
pattern is reinforced by the lack of care work
recognition within the Belgian, the Italian as
well as in the British (SERPS) scheme. In contrast,
the German and the Swedish (ATP)
scheme mitigate work behaviour discrimination
through relatively generous recognition of
care work which brings them close to the
medium discriminatory level.
The third cluster to be identified comprises
the remaining six schemes. This group is the
most heterogeneous and, therefore, it challenges
the analysis. The schemes are characterized
by high barriers to access ­ with the
exception of the Luxembourgian and especially
the French scheme ­ and medium levels
112 LEITNER
Journal of European Social Policy 2001 11 (2)
Table 9 Work behaviour discrimination in earnings-related schemes
Access Benefit base Number of years Child care Family care
Denmark
ATP-Scheme Low Low Low High High
Finland
ATP-Scheme Low Low Low High Low
Austria High Medium Medium Medium Medium
France Low Medium Low Medium High
Greece High Low Medium High High
Luxembourg Medium Medium Low Medium High
Portugal High Medium Low Medium High
Spain High Medium Medium High High
Belgium Low High Medium Medium High
Germany Low High High Medium Low
Italy Low High High High Medium
Sweden
ATP-Scheme Low High High Medium Low
United Kingdom
SERPS Low High High High High
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 113
Journal of European Social Policy 2001 11 (2)
of discrimination in the categories `Benefit
base', `Number of years', and `Child care'.
Only the Greek and Spanish schemes deviate
to a remarkable degree since they nearly completely
lack recognition of care work and consider
up to 45 years of insurance coverage.
If we add the dimension of care discrimination
to the above four clusters, we get a
slightly altered, but integrated picture (see
Table 10). The gender neutrality cluster contains
two subgroups, the second of which
(b) shows care discrimination whereas the first
(a) does not. The low discrimination cluster is
similarly split. Whereas Finland does provide
survivor benefits, Denmark does not.
Interestingly, Sweden has to be grouped with
Denmark since its earnings-related scheme
does not contain care discrimination and the
pension provisions for care work are comparably
high, so that they counterbalance the
strong link to average lifetime earnings and
long contribution periods. The medium discrimination
cluster as well as the high discrimination
cluster remain nearly unchanged since
all of these schemes show care discrimination.
Besides the Swedish case discussed above,
there is only one exception: due to the relatively
generous recognition of care work,
Germany was taken out of the high discrimination
cluster and added to the first subgroup
(a) of the medium discrimination cluster.
After all the details about the different
pension schemes and how they institutionalize
mechanisms of gender discrimination, one
question remains to be answered: What would
be the preferable country for women's old age
security? This poses a problem since a
country's old age security system represents a
mixture of different pension schemes which
includes a public/private mix as well as different
income provisions from state-organized
schemes. On the one hand, pension systems
that encourage private provision will tend to
favour men over women, as will earningsrelated
public pensions. On the other hand,
universal schemes and flat-rate benefits will
tend to equalize men's and women's incomes
in retirement (Hutton and Whiteford, 1994:
206­7).
Following Jay Ginn and Sara Arber (1992:
258­9), three models of pension systems can
be distinguished in Western Europe: the residual
model, the income security model, and the
basic security model. The residual model
includes the United Kingdom and Ireland `countries
where the minimum pension is
inadequate and conditional on the contribution
recorď and where occupational and
private pension schemes top-up the earningsrelated
benefits of those in better jobs. In the
income security model, state-organized earnings-related
schemes constitute the main
element of the old age security system. Here
we find the Continental and the Southern
European countries: Austria, Germany,
Belgium, France, Luxembourg, Greece, Italy,
Spain, and Portugal. Finally, the basic security
model provides a basic pension to all citizens
regardless of their work record and in addition,
state earnings-related or occupational
pension schemes play an important role for
income security in old age. The model comprises
the Scandinavian countries and the
Netherlands. Ginn and Arber found `that
those who are for any reason disadvantaged in
employment, especially women with domestic
Table 10 Clustering European pension schemes
Clusters Pension schemes
Gender neutrality (a) DK, SF, NL, S
(b) IR, UK (Basic Pension)
Low discrimination (a) DK (ATP), S (ATP)
(b) SF (ATP)
Medium discrimination (a) A, F, D, L, P
(b) GR, E
High discrimination B, I, UK (SERPS)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
responsibilities, are more likely to receive an
adequate pension in their own right where the
pension system approximates to the "basic
security" model (such as Denmark) rather
than the "income security" (Germany) or
"residual" (UK) modeľ (1992: 268). Thus, for
women with typically female labour-market
careers, the countries with universal pension
schemes would provide best in old age; above
all Denmark, since links between earnings and
pension income are weak there. However,
women with continuous full-time careers in
well-paid jobs would benefit more from the
income security or the residual model since
benefits are higher in earnings-related schemes
than in universal schemes (Hutton and
Whiteford, 1994). Lastly, women without (or
with a small) independent pension income
would be better off in countries with survivor
benefit schemes, but only if they were
married, otherwise the universal schemes
would be the better choice. Therefore the conclusion
picks up the starting point which was
the differences among women. What we
choose as the preferred old age security system
for women depends on which subgroup of
women we are talking about. It depends on
their work behaviour: whether they are
employed or family carers, whether they are
continuously or discontinuously employed,
whether they are employed part time or full
time and how much they earn from employment.
It also depends on women's care
arrangements: whether they are married or
widowed, single or living in alternative partnerships
and alternative household arrange-
ments.
Acknowledgements
This paper is based on a presentation given at
the SPA-Study Day `Women, Risk, and Social
Policy' (4 March 2000 at the London School
of Economics). I am grateful for comments
which arose from the discussion there. I especially
wish to thank Jay Ginn for her most
valuable suggestions. I am also indebted to the
anonymous referees who provided useful
advice for revising the first draft of the paper.
Lastly, I cordially thank Elisa Chuliá for her
comments and Angelika Maser for her linguistic
support.
Notes
1 Norway is an exception with regard to public
child-care provision (Leira, 1994).
2 Because women have to juggle the double
burden of employment and family work ­ it is
argued ­ they should be rewarded by lowering
their pension age; and because women are hindered
in gaining individual pension rights due to
their family work responsibilities ­ it is argued they
should receive a survivor pension after the
family breadwinner's death (Luckhaus and
Ward, 1996).
3 The Netherlands did not formally establish a
state-organized employment-related pension
scheme, but more than 95% of workers are
covered by earnings-related pension schemes,
mainly through obligatory collective labour
agreements.
4 It has to be noted that in Denmark benefits are
based on the number of hours employed, which
discriminates against part-time employment.
5 For empirical evidence, see e.g. Rake (1999) who
compares Britain, France and Germany with
respect to women's and men's income in old age.
6 Those earnings-related schemes may be stateorganized
or private occupational schemes; some
countries have both. The analysis excludes
private schemes. It can be supposed, though, that
private schemes reinforce inequalities between
men and women (Hutton and Whiteford, 1994).
7 It should be noted that those universal schemes
do not automatically provide a sufficient
minimum income (Döring et al., 1994). Hutton
and Whiteford (1994) even suggest that a high
degree of gender equality in terms of retirement
income is closely linked to low benefit levels.
References
BMA (Bundesministerium für Arbeit und
Sozialordnung) (ed.) (1999) Euroatlas. Soziale
Sicherheit im Vergleich. Bonn: BMA (Referat
Öffentlichkeitsarbeit).
114 LEITNER
Journal of European Social Policy 2001 11 (2)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from
Butler, J. (1990) Gender Trouble: Feminism and the
Subversion of Identity. London: Routledge.
Butler, J. (1993) Bodies that Matter: On the
Discursive Limits of `Sex'. London: Routledge.
Daly, M. (1997) `Welfare States under Pressure:
Cash Benefits in European Welfare States over
the Last Ten Years', Journal of European Social
Policy 7 (2): 129­46.
Döring, D., Hauser, R., Rolf, G. and Tibitanzl, F.
(1994) `Old-age Security for Women in the
Twelve EC Countries', Journal of European
Social Policy 4 (1): 1­18.
Esping-Andersen, G. (ed.) (1996) Welfare States in
Transition. National Adaptations in Global
Economies. London: Sage.
Gerhard, U., Schwarzer, A. and Slupik, V. (eds)
(1988) Auf Kosten der Frauen. Frauenrechte im
Sozialstaat. Weinheim/Basel: Beltz Verlag.
Ginn, J. and Arber, S. (1992) `Towards Women's
Independence: Pension Systems in Three Contrasting
European Welfare States', Journal of
European Social Policy 2 (4): 255­77.
Gordon, L. (1994) Pitied but not Entitled. Single
Mothers and the History of Welfare 1890­1935.
New York: The Free Press.
Hernes, H. M. (1989) Wohlfahrtsstaat und
Frauenmacht. Essays über die Feminisierung des
Staates. Baden-Baden: Nomos.
Holter, H. (ed.) (1984) Patriarchy in a Welfare
Society. Olso: Universitetsforlaget.
hooks, b. (1984) Feminist Theory: from Margin to
Center. Boston, MA: South End Press.
Hutton, S. and Whiteford, P. (1994) `Gender and
Retirement Incomes: a Comparative Analysis', in
S. Baldwin and J. Falkingham (eds) Social
Security and Social Change. New Challanges to
the Beveridge Model, pp. 199­215. London:
Harvester Wheatsheaf.
Kickbusch, I. and Riedmüller, B. (eds) (1984) Die
armen Frauen. Frauen und Sozialpolitik.
Frankfurt/Main: Suhrkamp.
Klammer, U. (1997) Alterssicherung in Italien. Eine
institutionelle, theoretische und empirische
Analyse. Berlin: Duncker & Humblot.
Langan, M. and Ostner, I. (1991) `Geschlechterpolitik
im Wohlfahrtsstaat: Aspekte im internationalen
Vergleich', Kritische Justiz 24 (3):
302­17.
Leira, A. (1994) `Erwerbstätige Mütter und
Wohlfahrtsstaaten. Konzepte von Mutterschaft:
Mütter als Erwerbende und Betreuende', in E.
Appelt and G. Neyer (eds) Feministische
Politikwissenschaft, pp. 159­82. Wien: Verlag für
Gesellschaftskritik.
Leitner, S. (1999a) Frauen und Männer im
Wohlfahrtsstaat. Zur strukturellen Umsetzung
von Geschlechterkonstruktionen in sozialen
Sicherungssytemen. Wien: Lang.
Leitner, S. (1999b) `Implementing the Philosophical
Differentiation between Gender and Sex. A
Gainful Feminist Approach towards Structural
Analyses of Social Policy', paper presented at the
international and interdisciplinary conference
`Gender and Markets in the Reconstruction of
European Welfare States' (July), University of
Bremen.
Lewis, J. (1992) `Gender and the Development of
Welfare Regimes', Journal of European Social
Policy 2 (3): 159­73.
Lewis, J. (ed.) (1998) Gender, Social Care and
Welfare State. Restructuring in Europe.
Aldershot: Ashgate.
Luckhaus, L. and Ward, S. (1996) `Gleiche
Rentenansprüche für Männer und Frauen: eine
realistische Perspektive?', in A. Bosco and M.
Hutsebaut (eds) Sozialer Schutz in Europa.
Veränderungen und Herausforderungen, pp.
167­94. Marburg: Schüren.
Nelson, B. (1990) `The Origins of the Two-channel
Welfare State: Workmen's Compensation and
Mother's Aiď, in L. Gordon (ed.) Women, the
State, and Welfare, pp. 123­51. Madison: The
University of Wisconsin Press.
Pearce, D. (1978) `The Feminization of Poverty:
Women, Work and Welfare', The Urban and
Social Change Review 2 (1+2): 28­36.
Pearce, D. (1993) `Something Old, Something New:
Women's Poverty in the 1990s', in S. Matteo (ed.)
American Women in the Nineties. Today's
Critical Issues, pp. 79­97. Boston, MA:
Northeastern University Press.
Rake, K. (1999) `Accumulated Disadvantage?
Welfare State Provision and the Incomes of Older
Women and Men in Britain, France and
Germany', in J. Clasen (ed.) Comparative Social
Policy: Concepts, Theories and Methods, pp.
220­45. Oxford: Blackwell.
Sainsbury, D. (ed.) (1994) Gendering Welfare States.
London: Sage.
Sainsbury, D. (1999) Gender and Welfare State
Regimes. Oxford: Oxford University Press.
Schaffner Goldberg, G. and Kremen, E. (eds) (1990)
The Feminization of Poverty. Only in America?
New York: Greenwood Press.
Skocpol, T. (1995) Protecting Soldiers and Mothers.
The Political Origins of Social Policy in the
United States. Cambridge, MA: Harvard
University Press.
GENDER DISCRIMINATION WITHIN EU PENSION SYSTEMS 115
Journal of European Social Policy 2001 11 (2)
 2001 SAGE Publications. All rights reserved. Not for commercial use or unauthorized distribution.
at Uppsala Universitetsbibliotek on April 25, 2008http://esp.sagepub.comDownloaded from