Foreward

• By Daniel Bertossa, PSI General Secretary

Public Services International (PSI) commissioned the Global Labour Institute (GLI) to undertake this broad-based review of care across regions outside Latin America, following the groundbreaking advisory opinion issued in August 2025 by the Inter-American Court of Human Rights recognising care as a standalone human right. This review aims to shed light on the current landscape and to inform a new phase of our work. 

The review produced by the GLI demonstrates that, outside Latin America, care systems are receiving increasing recognition as essential to both societies and economies; however, they remain uneven in development, fragmented in design, and rarely anchored in enforceable rights-based frameworks. Europe exhibits relatively advanced and coordinated systems yet faces growing inequalities linked to marketisation. In contrast, Africa, MENA, and the Caribbean display a common pattern of largely informal and under-resourced provision, heavily reliant on unpaid family and community care, and characterised by limited public infrastructure. In the Asia-Pacific region, diverse models coexist, with care systems increasingly shaped by privatisation trends alongside a persistent dependence on family-based and low-paid care work. North America remains highly market-driven, with some reforms improving access but falling short of establishing universal entitlements. 

Significant challenges remain. Advancing care as a human right has been one of PSI’s principal contributions to global debates, garnering strong support from allies within the human rights and feminist movements, while also provoking resistance and backlash from those seeking to commodify care. We are the workers within these uneven care systems, services, and programmes worldwide. PSI represents and amplifies the voices of public service care workers operating across public, private, non-profit, and community settings at national, local, and home-based levels. 

We are the care workers organising and resisting. 
We are the workers advancing care as a human right. 
We are the workers who will win the fight back. 

PSI extends its sincere appreciation to Georgia Montague Nelson for her tireless professionalism and dedication in making this outstanding review possible. 

Executive Summary

Care is fundamental to human survival, social reproduction, and economic functioning, yet it remains structurally undervalued, gendered, and inadequately supported across the world. Women continue to bear a disproportionate burden of unpaid care work while also being overrepresented in low-paid and precarious care employment. Decades of austerity, privatisation, and market-oriented reforms have weakened public care systems, resulting in fragmented provision, unequal access, and poor working conditions for care workers. In many parts of the Global South, care remains largely informal and family-based, with limited state involvement. 

In 2025 the Inter-American Court of Human Rights’ Advisory Opinion (OC-31/25) recognised care as an autonomous human right. This landmark decision establishes that care—including the rights to care, to be cared for, and to self-care—is not a policy option but a state obligation grounded in human dignity, equality, and social justice. It sets a new international standard requiring governments to guarantee access to quality care, protect care workers, and address the gendered distribution of unpaid care. 

Despite growing policy attention to care across regions—including expanded childcare systems, long-term care reforms, and recognition of unpaid care—most developments remain programmatic and fragmented rather than rights-based. Care continues to be embedded within labour, social protection, or welfare frameworks rather than recognised as a universal legal entitlement. Across Europe, Africa, Asia-Pacific, MENA, North America, and the Caribbean, systems remain uneven, underfunded, and often shaped by market forces, with persistent gaps in access, quality, and poor workforce conditions. 

This study provides a broad-based review of the current landscape of care across regions beyond Latin America, highlighting trends in privatisation, policy reform, and re-municipalisation. It finds that while care is increasingly recognised as essential social infrastructure, there is limited legal recognition of care as a human right outside of Latin America. Structural challenges—including chronic underinvestment, pervasive informality, weak labour protections, and entrenched gender inequality—continue to constrain inclusive development. These constraints are not merely incidental, they are rooted in deeper political economic dynamics shaped by implicit market forces and explicit power structures.  

The IACHR advisory opinion provides a critical opportunity to advance a global shift toward rights-based care systems. Achieving this requires moving beyond fragmented, market-reliant models toward universal, publicly financed systems grounded in legal entitlements. Trade unions and civil society play a central role in this transition, particularly through advocacy, collective bargaining, and coalition-building. Ultimately, recognising care as a human right requires a fundamental reorganisation of how care is valued, financed, and delivered—placing it at the centre of public policy, legal frameworks, and social justice agendas. 

1. Introduction

Care is the activities necessary to meet people’s basic needs and to sustain life. It is the social foundation that holds communities together and enables economies to function, and is essential for the reproduction of societies. Care can be either paid or unpaid, but globally it remains highly gendered: women are overrepresented in the paid care workforce (‘paid care workers’) and carry a disproportionate share of unpaid care responsibilities (‘unpaid care givers’) within households.

However, decades of austerity, neoliberal reforms, and privatisation have weakened these systems which means that provision often fails to meet societal needs, while care workers face low pay, precarious conditions, and exploitation. Across much of the Global South, formal social care systems remain limited or absent, with the State playing only a minimal role. Private provision can be prohibitively expensive, meaning that most care is provided informally within families and communities, predominantly by women.[I]

PSI’s Care Manifesto for Rebuilding the Social Organisation of Care,[II] launched in 2021, called for care to be recognised not as a commodity within the market economy but as a fundamental human right. It called for rebuilding care systems around a model that prioritises care for people over profit.

In 2025, the Inter-American Court of Human Rights (IACHR) reinforced this vision through a landmark advisory opinion recognising care as an autonomous human right. By doing so, the Court moved the concept of care decisively away from commodification and privatisation. The Court placed care firmly at the centre of the human rights agenda, affirming that care is a right that States have a duty to guarantee. This represents both a legal milestone and a major political breakthrough at the global level. It establishes an international standard that challenges governments worldwide to recognise, legislate for, and sustainably invest in care as a human right.

Study Objectives

The IACHR advisory opinion opens up new avenues for advancing the recognition of care rights in other regions. PSI aims to build momentum around this advisory opinion to support advocacy efforts for the recognition of care as a human right in national legislation. As part of this effort, this study provides a broad-based review of the current landscape of care across other regions with a particular focus on:

• Trends in the privatisation of care services

• Care policy and legislative initiatives, both advances and gaps

• Examples of re-municipalisation, or the return of care services to public provision

This review will help to identify opportunities and inform advocacy strategies to support the progressive realisation of care as a universally recognised human right.

This study combines desk-based literature review with a small number of targeted interviews to provide contextual insights and examples of policy development and implementation at regional levels.

The report covers the regions of Europe, Africa, Asia-Pacific, Middle East North Africa (MENA), North America and the Caribbean. This study is not intended to be exhaustive, instead for each region, the study provides a brief overview of the current situation and a small number of notable recent (typically within the past 5 years) examples of relevant legal frameworks or policy initiatives related to different types of care.

The IACHR advisory opinion opens up new avenues for advancing the recognition of care rights in other regions. PSI aims to build momentum around this advisory opinion to support advocacy efforts for the recognition of care as a human right in national legislation. As part of this effort, this study provides a broad-based review of the current landscape of care across other regions with a particular focus on:

• Trends in the privatisation of care services

• Care policy and legislative initiatives, both advances and gaps

• Examples of re-municipalisation, or the return of care services to public provision

This review will help to identify opportunities and inform advocacy strategies to support the progressive realisation of care as a universally recognised human right.

This study combines desk-based literature review with a small number of targeted interviews to provide contextual insights and examples of policy development and implementation at regional levels.

The report covers the regions of Europe, Africa, Asia-Pacific, Middle East North Africa (MENA), North America and the Caribbean. This study is not intended to be exhaustive, instead for each region, the study provides a brief overview of the current situation and a small number of notable recent (typically within the past 5 years) examples of relevant legal frameworks or policy initiatives related to different types of care.

2. IACHR Advisory Opinion - Care as an Autonomous Human Right 

In 2025, the Inter-American Court of Human Rights (IACHR) issued an advisory opinion in response to a request submitted in January 2023 by the Republic of Argentina’s Ministry of Women, Gender and Diversity regarding the content and scope of care as a human right, and its interrelationship with other rights.[III]

The Advisory Opinion 31 of 2025 (OC-31/25) was adopted on June 12, 2025 and was the first in which an international court was asked to address the right to care. The opinion clarifies the content and scope of the right to care, its relationship with other human rights and the obligations of states to guarantee it, with particular attention to equality, non-discrimination, and the protection of vulnerable groups. It outlines how governments across the Americas must safeguards the rights of people who provide care and those who depend on it.[IV]

The opinion represents a major legal and political shift. Care is recognised as an autonomous human right. It reframes care away from private responsibility, commodification and privatisation and instead situates it within the framework of state obligations under international human rights law. It affirms that governments must guarantee access to care, ensure quality and continuity of services, and protect the rights and working conditions of those who provide care. It recognises care as a basic human need that everyone will require at some point during their life cycle, and as an independent right that encompasses the right to care, the right to be cared for, and the right to self-care. It also explicitly acknowledges that care work—both paid and unpaid—is essential to human dignity and must be legally recognised and protected.[V]

The opinion places care as a right that states must actively guarantee, setting out a clear framework for state responsibilities:

• Protection of paid care workers: States should adopt policies to ensure decent working conditions in the care sector (fair and equal pay, job security, safe and healthy working environments, limits on working hours, rest periods and leave, freedom of association and the right to collective bargaining, workplace protections). These rights apply whether workers are employed informally or formally, including domestic workers and home-based workers. [VII]

• Addressing unpaid care work: Unpaid care work is disproportionately performed by women and must be addressed through public policy. States are expected to prevent human rights violations linked to unpaid care by – developing comprehensive care systems, providing parental leave and flexible working arrangements, ensuring access to social protection and social security, guaranteeing pensions, parental benefits and support for caregivers, and adopting measures to allow workers with family responsibilities to participate in the labour market without discrimination.

• Protection of vulnerable groups: States should adopt strategies to protect vulnerable groups involved in care work including migrant domestic workers and others exposed to exploitative conditions.

If implemented at the national level it could lead to improved conditions and recognition for paid care workers, social protection and support for unpaid caregivers, a legal right to quality care for care recipients, and greater participation of women and marginalised groups in all parts of life.

Trade unions and civil society have a critical role to play in translating the opinion into practical reforms. However, limited political will, fiscal constraints, weak enforcement of labour laws, high levels of informality and persistent gender stereotypes will pose challenges to implementation.

3. Current Regional Landscape beyond Latin America 

This section provides a broad-based overview of the current situation regarding policies and legal frameworks across five regions, highlighting progress and challenges, and noting examples of relevant legislative or policy initiatives.  

Outside of Latin America, a growing number of governments are developing care policies and strategies, with several cross-cutting themes emerging. These include an expanded role for the private sector in care provision, a continued reliance on informal and unpaid care work, and the predominance of reforms that are ‘rights-adjacent’, rather than grounded in enforceable entitlements.

At the same time, there have been notable policy efforts to address inequalities affecting both unpaid caregivers and paid care workers. These initiatives include expanding childcare and long-term care systems, strengthening labour protections and social security for paid care workers, and increasing recognition of the social and economic value of care. However, often policy debates remain narrowly framed. They often prioritise recruitment and retention challenges, or focus on enabling women’s labour market participation through measures such as parental leave and flexible working arrangements. In many contexts, care provision is embedded within targeted welfare programmes and treated as a social policy instrument, which can restrict access to specifical populations rather than establishing universal entitlements. As a result, explicit legal recognition of a universal and autonomous right to care – alongside guarantees of universal access and clear state responsibility for provision – remains limited. Care continues to be predominantly framed through labour market, social protection or gender equality lenses, rather than as a standalone right.

Europe

Across Europe, care systems increasingly operate through mixed provision models that combine public funding with service delivery by public, private and non-profit actors. These arrangements are supported by mechanisms such as care vouchers and subsidies, outsourcing of care services, and insurance-based financing systems, which in some countries allow users to choose between competing providers.

Over recent decades, European care systems have undergone significant marketisation and privatisation. This has involved the expansion of for-profit providers - including multinational corporations - alongside increased outsourcing to private bodies and decentralisation of responsibilities to local governments, often without adequate funding and with policy framework that encourage market-based provision. Evidence suggests that market competition has not consistently improved efficiency or quality. Instead, privatisation has frequently been associated with challenges in service access and regulation, as well as deteriorating workforce conditions, including lower wages, greater precarity, and staffing shortages. The growing presence of multinational corporations and financial investors has further contributed to the financialisation of care, raising concerns about accountability, profit extraction, and long-term system sustainability.[X]

Policy Context

Care policy in Europe is shaped by the interaction between national systems and European Union (EU) governance frameworks. Recent reforms have prioritised the expansion of childcare and long-term care services in response to ageing populations, labour shortages in the care sector, and efforts to increase women’s labour market participation.

While care provision has expanded, care is rarely recognised as a standalone, enforceable right. Instead, it is typically embedded within labour market regulation, social insurance systems, and service delivery systems, resulting in signification variation across countries. Progress has been made in strengthening care-related rights (parental leave, flexible working arrangements, employment protections), alongside growing recognition of informal carers and efforts to professionalise care work (improved wages, labour standards, development of professional qualifications, and OSH measures).

Re-municipalisation of Care Services

Despite dominant trends towards marketisation, some municipalities have pursued re-municipalisation, bringing care services back under public control as a deliberate strategy. This has included for example:

• Bergen, Norway (2016): gradual return of privately run nursing homes to municipal management due to concerns over outsourcing and labour conditions.[XI]

• Oslo, Norway (2017): shift away from private tendering towards expanded municipal provision, alongside a broader strategy to reduce outsourcing and increase public employment.[XII]

• Barcelona, Spain (2015-present): implementation of a ‘caring city’ agenda linking social services, gender equality and urban governance, with a focus on expanding direct public provision.[XIII]

• Germany (2015-present): within its insurance-based long-term care (LTC) system, established in 1995, there has been some expansion of municipal care companies, publicly owned providers have expanded public provision, and in some cases, intervened to stabilise or take over services where private provision has been unstable (EU Commission & Social Protection Committee 2021.) [XIV]

Europe provides some of the clearest examples of re-municipalisation being framed as a policy choice.

European Care Strategy

The European Care Strategy – adopted in 2022 – provides a framework for strengthening care systems across the EU. It was developed over several years through a policy process by the European Commission, following a commitment to propose a comprehensive framework to address care needs across the life course. Its development involved consultations with states, trade unions, civil society, care providers and employers’ organisations. The strategy includes the Care Strategy and two Council Recommendations on early childhood education and care, and on long-term care.[XV]

The Care Strategy (and recommendations) encourages Member States to develop national-level reforms, including care strategies and investment plans that enhance care access and quality:[XVI]

• Recognises Care as Essential Social Care Infrastructure: emphasises the importance of ‘accessible, affordable, and high-quality care services’ and frames care as essential to social well-being, gender equality and economic sustainability and necessary to enable women’s labour-market participation, support work-life balance and ensure dignified living conditions for people needing care.

• Expansion of Early Childhood Education and Care (ECEC): encourages members states to expand childcare coverage, and emphasise affordability and accessibility, quality standards and workforce development, and inclusion of children from vulnerable backgrounds,

• Development of Sustainable Long-Term Care (LTC) Systems: includes the Council Recommendation on Long-Term Care, calling on states to ensure access to affordable LTC services, expand home and community-based care, integrate health and social care services, and develop national LTC strategies to address ageing populations.

• Support and Recognition of Informal Carers: recognises the role played by informal and family caregivers, calling on states to provide adequate social protection and income support, expand counselling and support services, ensure access to training and information, and implement work-life balance

• Strengthening the Care Workforce: commitments to improve working conditions, wages, and labour standards, training and professionalisation, support occupational safety and health, and address labour shortages and needs through workforce planning

• Quality, Regulation and Governance: encourages the establishment of quality frameworks, monitoring mechanisms, data collection, regulation of providers and sustainability public financing for care systems

The strategy is anchored in the European Pillar of Social Rights. It emphasises dignity, accessibility, affordability, quality and gender equality. Implementation is monitored through EU governance processes through which Member States report on reforms and progress.

Despite its policy significance, the strategy does not establish legally enforceable rights to care. Instead it frames care as rights-adjacent and primarily as social infrastructure, labour-market support, and social protection. As soft governance tools, it relies on non-binding recommendations and voluntary national implementation. The European Commission is paying attention to Member States that are falling behind in care provision and has indicated plans to strengthen the agenda through future initiatives. Commission future programming also references a possible European Care Deal in 2027, although its scope and content remain uncertain.

National-Level Reforms

Across Europe, national level implementation shows uneven but substantive progress:

• Policy responses from two-thirds of Member States focus on expanding availability of services and addressing workforce challenges.

• Just over half of Member States report measures aimed at improving the adequacy and quality of care services and strengthening support for informal carers (European Commission, 2025.)[XVII]

• There is also growing attention to improving governance and coordination, and promoting evidence-based policymaking.

However significant challenges remain including persistent workforce shortages and precarity, limited availability of services, ongoing disparities across countries, challenges in ensuring consistent quality of care, and weak integration and coordination across care systems. A key issue is the difficulty of securing adequate and sustainable financing. Nordic countries continue to be strong performers, characterised by well-developed childcare systems and comprehensive parental leave arrangements, whereas others – such as Ireland – continue to face significant challenges in availability and affordable of early childcare.

Across Europe, national reforms tend to fall into key categories including:

• workforce regulation and professionalisation (improving working conditions, training, education and career pathways, recruitment and retention, labour protections)

• development of LTC systems and insurance-based models, providing legal entitlements to services and framing care as a social risk within welfare systems

• recognition and support for informal carers

• expansion of services and infrastructure, including childcare and long-term care capacity, community-based care models, deinstitutionalisation and greater coordination.(European Commission, 2025.) [XVIII]

Recent childcare reforms illustrate different policy approaches focused on capacity expansion, workforce measures and quality improvement, including for example:

• Germany, Kita Quality Act (2022): focuses on improving the quality of provision, including staff conditions, and early education support

• Poland, Active Toddler Programme (2022-2029): large-scale expansion of childcare places combined with national quality standards

• Netherlands, Workforce Flexibility Reform (2022-2026): regulatory adjustments to address staff shortages, including increased use of trainees

• Italy, Recovery and Resilience Plans (post 2022): investment in childcare infrastructure aimed at reducing regional inequalities.

Examples of Long-Term Care System reforms include:

Social Insurance & System Development

• Slovenia (2023-present): introduction of compulsory LTC insurance with standardised needs assessment and legal entitlements, framed within an insurance model, assessed by need, rather than universal right.[XIX]

• France: (2020-present): creation of a fifth branch of social security addressing loss of autonomy, alongside the ‘Ageing Well’ strategy to strengthen support for older persons and home care professionals (professional ID cards, and travel allowances) focused on dignity, autonomy, and workforce support.[XX]

Service expansion, community-based care and improved governance and oversight, although largely programme-based interventions, rather than universal guarantees.

• Italy (2021-present): reforms promoting independent living and deinstitutionalisation, and strengthening local social services capacity

• Greece (2024-present): development of an integrated LTC strategy and a shift towards community and home-based care

• Slovakia (2021-present): transition to community-based care models, introduction of personal care budgets for care recipients, and creation of central supervisory authority

• Bulgaria (2022-present): introduction of national quality standards, and mapping and regulation of social services

• Croatia (2021-present): development of community-based services through the National Plan for the Development of Social Services (2021-2027)

• Malta (2016-present): expansion of ‘Carer at Home’ scheme, first introduced in 2016 with subsequent funding increases, which provides financial assistance to elderly individuals hiring a qualified carer.[XXI]

• Portugal (2023-present): investment in expanding and modernising social care service networks, to develop more efficient service delivery, coverage and improve working conditions in the sector (including Active and Healthy Ageing Action Plan 2023-2026)

Several countries have introduced reforms aimed at improving working conditions and professionalising standards in the care sector, often as part of broader efforts to address workforce shortages and strengthen service quality. Reforms focus on career progression, education, training strengthening standards, fair wages, health and safety and recruitment and retention:

• Germany (2022 & 2024): reforms introduced in link reimbursement under LTC insurance schemes to compliance with sectoral wage standards – in line with collective wage agreements - using financing mechanisms to raise labour standards in the sector.[XXII]

• Spain (2022 & 2023): Professionalisation reforms including training, wage increases, and de-institutionalisation strategies.[XXIII]

• Finland: Programmes introduced (2024-2027 and 2021-2023) to support workforce wellbeing and career development

• Sweden (2023-present): introduction of protected professional title for nursing assistants in 2023, alongside expanded training and upskilling initiatives for staff working in elder care.

• Austria (2016-present): expansion of community nursing networks and investment in workforce training and career pathways and sector-wide collective agreements

• Denmark (2023-present): mentoring and training initiatives to improve retention

Persistent challenges include high levels of undeclared work, limited access to labour and social protection, weak enforcement of labour rights and occupational health and safety concerns.

Recognition of informal carers, although measures remain partially conditional or means tested and often embedded within existing welfare and labour systems.

• Portugal (2019-present): establishment of comprehensive legal framework recognising informal carers in 2019, including financial allowances, training and psychological support, labour and social protection and expanded eligibility in 2023 / 2024 reforms.[XXIV]

• France (2023-present): recognition of informal care experience through validation of prior learning (2023-2027 ‘Acting for Caregivers’ Strategy)

• Belgium (2023): formal recognition of and expanded roles for care workers, enabling informal caregivers to carry out certain tasks under supervision, offering them a formal career track

Across Europe, care reforms demonstrate incremental strengthening of care systems, particularly in workforce regulation, service expansion, system coordination and support for informal carers. However, most reforms are framed within labour market policy, social insurance systems, and service delivery frameworks rather than as part of a comprehensive, rights-based approach to care.

As a result, care is typically treated as a social risk or policy domain, not an enforceable right. Entitlements remain conditional, fragmented and uneven across countries. Progress exists with persistent structural gaps, particularly in workforce sustainability, access and financing.

EU Work-Life Balance Directive (2019/1158)

A key legislative instrument shaping care policy in Europe is the EU Work-Life Balance Directive (2019/1158) which establishes minimum employment rights for workers with caregiving responsibilities.[XXV] The Directive sets EU-wide minimum standards including:

• A minimum of 4 months of parental leave per parent

• 10 days of paternity leave

• 5 days of carers’ leave annually for workers providing personal care

• The right to request flexible working arrangements

• Protection against discrimination or dismissal for parents and carers

Several countries have met or expanded beyond these minimum standards, for example:

• Sweden provides up to 100 days of paid carers’ leave, with approximately 80% wage replacement

• Germany offers 10 days of paid carers’ leave and up to 6 months of unpaid leave

• Italy provides flexible paid leave (e.g. 3 days per month for elder care)

• Denmark allows up to 6 months of unpaid care leave

• Poland and Slovenia have introduced 5 days of carers’ leave annually

• In Italy and Luxembourg, it is mandatory to take the full duration of paternity leave, reinforcing uptake

Despite these advances, a critical policy gap remains between the end of maternity (or parental) leave and access to affordable, available childcare services. Where this gap persists families may be forced to withdraw from the labour market, there is increased reliance on informal or private care arrangements, and gender inequalities in care responsibilities are often reinforced.

The directive is an important step in recognising the social and economic value of caregiving, strengthening labour market protections for unpaid caregivers, and promoting a more equal distribution of care. However, the approach is primarily employment-centred. Care is positioned as a social risk that triggers workplace rights. Access to these rights is therefore connected to participation in the labour market. This can be a pathway to embedding care as a human right in the workplace context.

UK: National Care Service

In the United Kingdom, proposals for establishing a National Care Services have been advanced as part of wider discussions on reforming adult social care and addressing longstanding problems of access, quality and funding. Drawing from the principles of the National Health Service (NHS), the aim is to introduce more consistent national standards, improved working conditions and greater care coordination across the country.[XXVI] To support the reform agenda, an independent commission on adult social care has been established to examine options for system redesign. However the proposals remain at an early agenda-setting stage.

EU-Latin America and Caribbean Bi-Regional Pact on Care

The EU, plus 16 countries of Latin America and Caribbean launched a pact to put the wellbeing, dignity and equality at the centre of care policy cooperation. Together, they have established a forum for ongoing dialogue to strengthen care systems, improve access to quality and affordable care services, and promote equitable distribution of responsibilities between families, government and the private sector.

Summary

Care policy across Europe has evolved significantly, shaped by EU-level frameworks and diverse national reforms. Notable progress includes the expansion of services, efforts to address workforce shortages, improvements in quality, and stronger recognition and support for informal carers, alongside enhanced governance, coordination and evidence-based policy-making. EU initiatives have been instrumental in setting common priorities and benchmarks, particularly around accessibility, affordability, quality, workforce development and gender equality.

However, these advances remain embedded within mixed provision models shaped by marketisation, decentralisation and financial constraints. These dynamics continue to generate challenges in access, service quality and workforce conditions, while raising concerns about the long-term sustainability of care systems. In response, some municipalities have pursued re-municipalisation, reflecting renewed interest in strengthening public provision. EU-level frameworks rely on soft governance mechanisms, resulting in uneven implementation cross Member States.

National reforms have focused on workforce regulation and professionalisation, the development of long-term care systems, expanded support for informal carers and the scaling up of care services and infrastructure – including a shift toward community-based and deinstitutionalised models. While these reforms have strengthened care systems, they remain largely framed within labour market policy, social insurance and service delivery structures, rather than as part of a comprehensive rights-based approach. Consequently, care continues to be treated predominantly as a social service, labour market support or insurable social risk, rather than as a universal and enforceable human right. Although recent policy frameworks increasingly reference principles such as dignity, autonomy and gender equality, access to care remains conditional, fragmented and unevenly realised.

Africa

Care Systems & Trends

Across Africa, care systems are characterised by limited public provision, high levels of informality and a structural reliance on unpaid labour within households and communities. Care responsibilities are disproportionately borne by women and girls, who are estimated to perform around 70% of unpaid domestic and care work, reflecting deeply embedded gender norms and inequalities.[XXVII]

Public investment in care infrastructure remains low, resulting in systems where responsibility for care is left to families and communities, rather than supported through comprehensive public systems. Care arrangements are therefore fragmented, unevenly distributed across urban and rural areas, and heavily dependent on family networks and informal community support structures.

A defining feature of these systems across the region is a high degree of informal labour, with much care work carried out by domestic workers, community health workers and other informal care workers. These workers tend to be excluded from formal labour regulations and lack access to social protection, labour rights or health and safety protections. The household as a workplace often remains weakly regulated or legally ambiguous, reinforcing precarious working conditions.

These structural dynamics are further compounded by fiscal and macroeconomic constraints. Regressive taxation systems fail to reduce, redistribute and reward paid and unpaid care givers, and instead place a disproportionate burden on caregivers, especially women. At the same time, chronic underinvestment in public services shifts the burden of care provisions onto households, forcing women to act as ‘shock absorbers’ for gaps in healthcare, childcare, and social protection systems.

In many contexts, these constraints are reinforced by external policy influence and global economic governance. Institutions such as the International Monetary Fund (IMF) and the World Bank have played a significant role in shaping fiscal policy through conditionalities that prioritise austerity and debt servicing over social investment. These approaches are embedded within aid frameworks and privatisation agendas, further limiting state capacity to expand care systems.

More broadly, these outcomes reflect deeper structural constrains rooted in global and domestic power relations. Many of the barriers to care system development are not incidental but are sustained through policy choice and economic structures that reinforce existing inequalities and limit transformative investment in care.

Policy Context

Despite these challenges, care policy across Africa is gradually evolving. Governments are increasingly expanding social protection programmes, maternity protection and family-related benefits, and community health and care initiatives, alongside efforts to strengthen labour protections for care workers, particularly domestic workers. There is also a growing recognition of care as a central economic and social issue linked to development, social inclusion and women’s empowerment. A significant milestone has been the adoption and increasing national-level ratification of the ILO Convention 189 on Decent Work for Domestic Workers (ILO 2011.) [XXVIII], which has increased visibility of domestic work as a form of labour and encouraged national-level reforms to improve working conditions, wages and legal protections. Regional policy agendas increasingly incorporate care within broader frameworks on gender equality, social protection floors and inclusive economic growth.

However, care policy frameworks remain partial and fragmented. Care is typically addressed indirectly through sectoral policies – such as health, labour or social protection – rather than through integrated, system-wide strategies. Explicit legal recognition of a right to care, or to be cared for, is largely absent. As a result, despite growing policy attention, structural constraints - including underinvestment, informality, fiscal limitations and fragmented governance - continue to restrict the development of accessible, equitable and rights-based care systems across the region.

African Commission on Human and Peoples’ Rights – Resolution 584 and Emerging Guidelines on Informal Economy Work

In 2024, the African Commission on Human and Peoples’ Rights (ACHPR) adopted Resolution 584 (LXXVII) mandating the development of Guidelines on the Protection of the Rights of Workers in the Informal Economy.[XXIX] This marks an important step in recognising the scale and structural importance of informal economy work across Africa. The resolution highlights several critical realities:

• 8 out of 10 workers in Africa are in informal employment, playing a significant role in African national economies.

• Women are over-represented in the informal economy.

• Workers in the informal economy are excluded from labour and social protections, which can result in criminalisation of their activities.

In response, the ACHPR tasked its Working Group on Economic, Social and Cultural Rights – working in collaboration with the Special Rapporteur on the Rights of Women in Africa, trade unions and civil society - to develop regional guidelines and a model law to support national implementation. The guidelines, expected to be presented to the commission in 2026, aim to establish normative standards on extending labour rights and social protection to informal economy workers, advancing gender equality and non-discrimination, and protecting informal livelihoods from criminalisation.

Although not legally binding, the guidelines have the potential to serve as an important normative framework within the African human rights system. They can support domestic legal interpretation, inform litigation, and provide a basis for policy reform and advocacy. Their impact, however, will depend on the extent to which they are translated into national law and practice.

While the guidelines do not establish care as an autonomous human right, they are highly relevant to care work. Care is recognised as a structural determinant of the enjoyment of rights – shaping access to equality, dignity, decent work, and social protection. A significant proportion of care workers, including domestic workers and community-based care workers - operate within the informal economy and are therefore directly affected by the protections under development. By addressing informality, the guidelines could extend labour and social protections to care workers, strengthen recognition of the gendered nature of care work, and integrate care more explicitly into labour rights discourse.

This creates important opportunities for advocacy. Embedding care within a broader informal economy rights framework enables strategies that reflect the lived realities of workers – particularly women – while highlighting the intersections between care work and other forms of informal labour. Current advocacy efforts are therefore focused on ensuring that care work is explicitly recognised within the scope of the guidelines. The next phase will involve translating these emerging standards into practice, including aligning them with existing human rights obligations, preparing litigation and advocacy strategies, engaging national governments on policy reform, and strengthening visibility of domestic and care work with regional and national agendas.

Protocol on Social Protection and Social Security (2022)

The African Union Protocol on Social Protection and Social Security (2022) represents a major regional policy development, reflecting long-standing advocacy by African trade unions and the global labour movement for universal social protection systems. The Protocol establishes a framework requiring states to strengthen national social protection systems and ensure access to social security across the life course.[XXX] It is grounded in international standards, including ILO Convention No.102 on Social Security and ILO Recommendation No.202 on Social Protection Floors and signals an increasing recognition of social protection as a human rights issue.

The Protocol emphasises inclusivity, rights-based approaches, and responsive to vulnerable and marginalised groups, and calls on states to develop comprehensive national systems for delivering social protection and social services. It assigns primary responsibility to national governments for the development, governance and delivery of social protection systems, beginning with the adoption of adequate national legislation.[XXXI]

Importantly, the Protocol includes provisions directly relevant to care. Article 17 requires states to take measures to strengthen care systems and social services including “develop regulatory frameworks for caregivers and care services…strengthen the social service workforce…promote coordination and integration of social services and care-related support systems.” This represents a meaningful step in recognising care within broader social policy and linking care to state responsibilities for social protection.

However, the Protocol has several limitations. Ratification and national-level implementation remain limited, and care is primarily framed within social protection and social service systems rather than as an autonomous, enforceable human right. Its effectiveness will depend on the extent to which states translate its provisions into national legislation, financing commitments, and institutional reforms. As such, while it establishes an important normative and policy foundation, its transformative potential for care systems remains reliant on national level and implementation.

Selected National-Level Reforms

Kenya

Kenya has emerged as a leading example in Africa of developing a comprehensive and increasingly system-oriented approach to care policy, with a strong emphasis on unpaid care work and its implications for women’s rights and economic participation. A key milestone was the work of the Kenya National Bureau of Statistics, which in 2025 produced the country’s first official estimate of the economic value of unpaid domestic and care work. [XXXII] This has strengthened the evidence base for care policy, drawing on national time-use survey data.[XXXIII]

Building on this foundation, Kenya has developed one of the first comprehensive national care policy frameworks in Africa,(State Department for Gender and Affirmative Action, 2023) [XXXIV] led by the State Department of Gender and Affirmative Action, with support from partners including UN Women.

The policy explicitly addresses both unpaid caregivers and paid care (domestic) workers, while also aiming to expand and improve care services. The framework is anchored in the ILO 5Rs approach – Recognise, Reduce, Redistribute, Reward and Represent.(Kenya National Care Policy (Final Draft), Republic of Kenya 2023.)[XXXV]

Key policy commitments include:

• Recognition of paid and unpaid care work as economically and socially important.

• Acknowledgement of the structural impact of unpaid care work on women’s rights and economic participation.

• Integration of care into national development planning, labour policy and social protection systems.

• Promotion of dignity, equality and progressive realisation of care-related rights, aligning with Sustainable Development Goal 5.

Proposed interventions include increased public investment in care services, development of care-friendly workplace policies, gender-responsive social protection measures, and investment in infrastructure and technologies (e.g. water, energy, transport) to reduce the time burden of care work. It also includes measures to improve conditions for paid care workers, including rewarding and representation of paid care workers and domestic workers, though these are less developed.[XXXVI]

Implementation is being pursued through a phased approach, beginning with pilot counties before wider national rollout. Importantly, it remains a policy framework rather than a binding legal instrument. While it represents a significant shift in recognising care within policy and budgeting frameworks, its impact will depend on sustained public investment, cross-sectoral coordination and implementation capacity. It reflects a broader trend of care being framed as a development and gender equality issue rather than a standalone legal entitlement.

South Africa

South Africa provides an important example of the partial integration of care into constitutional and social policy frameworks. The country’s relatively developed social protection system has created space for care-related issues to be addressed through rights-based jurisprudence.

A significant legal development occurred in 2025 with the Constitutional Court judgement in Van Wyk and Others v Minister of Employment and Labour.[XXXVII] The Court struck down discriminatory parental leave provisions in the Unemployment Insurance Fund (UIF) parental leave framework that treated different categories of parents unequally in their leave entitlement. The Court held that parental leave legislation must comply with the constitutional guarantees of equality and dignity, requiring reforms to ensure more equitable recognition of caregiving responsibilities across different types of parents.

The judgement is notable for recognising caregiving as a constitutionally relevant social responsibility and for explicitly linking unequal leave entitlements to structural gender inequalities. It established that legal frameworks must adapt to caregiving realities rather than reinforcing unequal outcomes. In doing so, it places positive obligations on the state – and indirectly on employers – to reform parental leave systems in line with principles of equality and non-discrimination.[XXXVIII]

However, the ruling stops short of recognising care as an autonomous legal category. Care is addressed indirectly through existing constitutional rights rather than as a standalone entitlement. This reflects both progress and limitation. While courts are increasingly willing to engage with care as a rights-relevant issue, it highlights the limitations as seen in other regions, with care increasingly recognised as rights-relevant, but remaining conceptually and legally embedded within other rights, rather than as a distinct entitlement. Notably, South Africa also expanded leave for fathers of newborn children from 3-10 days in 2018.

Parallel developments have been seen, including partial formalisation of community health workers (CHWs) from volunteer-based roles to formal employment. For many years, community health workers operated under highly precarious conditions, performing essential functions while receiving low stipends and lacking job security. Following sustained advocacy by trade unions, a major breakthrough was achieved including Resolution 1 in 2018, recognising CHWs as permanent public health employees, and 2020 integration of approximately 6,000 CHWs in Gauteng into the public health system with formal employment status and access to benefits. This represents a significant shift toward the professionalisation and formalisation of care work, although challenges remain in achieving full national coverage and consistent working conditions.[XXXIX] This progress remains uneven across other provinces, highlighting ongoing challenges in standardising protections for care workers.

Malawi

In Malawi, recent reforms indicate a growing policy focus on expanding social protection and strengthening protections for care-related work, particularly for domestic workers and workers in the informal economy.[XL]

The National Social Protection Policy (2024-2029) aims to reduce poverty and vulnerability while improving coordination across social protection systems.[XLI] Recent developments include efforts to expand access to social insurance mechanisms, strengthen labour protections for domestic workers, and pursue constitutional litigation challenging the exclusion of domestic workers from social protection schemes under existing employment and pensions legislation.

In addition, reforms to the Workers’ Compensation system are under consideration, including proposals to move from an employer-liability model toward a broader social insurance-based framework, which could extend coverage to a wider group of workers, including those in care-related roles..[XLII]

Efforts to formalise representation of workers are also underway, including the process to register a Community Health Workers Union, which could strengthen collective bargaining and improve working conditions.

These developments reflect increasing recognition of domestic and care work as legitimate forms of labour deserving of legal recognition, dignity, access to labour rights and social protection. However, the approach remains primarily anchored in labour law and social protection, focusing on worker protection rather than systemic transformation of care provision. Care is therefore addressed indirectly – through support for those providing care – rather than as a universal right.

Other national-level initiatives:

Across the region, a range of other national-level initiatives reflect growing policy attention to care, though these remain fragmented and often limited in scope:

• Uganda: proposed labour law reforms under the Employment Amendment Bill aim to formally recognise domestic workers as employees, including recognising households as workplaces, and strengthening labour inspection and worker protection mechanisms. These reforms represent an important step toward formalising domestic work and extending labour protections to care-related occupations, although remain primarily focused on employment regulation.[XLIII]

• Senegal: implemented a 3R programme – recognise, reduce, redistribute unpaid care work - within local government investment planning frameworks, signalling efforts to integrate care into public policy and budgeting processes.[XLIV]

• Mali: conducted a national time-use survey in 2023 to quantify the economic value of unpaid domestic and care work to build the evidence base for care policy and raise awareness of economic significance of unpaid care labour. This initiative makes care work visible within economic and policy frameworks, though do not establish rights or services.[XLV]

• Ghana: national consultations have highlighted the importance of incorporating unpaid care work into development planning frameworks and recognising women’s disproportionate care burden. These discussions reflect increasing recognition of care as a development and gender equality issue.

Summary

Across Africa, care is gaining increasing recognition within human rights, policy and development frameworks, particularly in relation to gender equality, labour rights and social protection. Regional initiatives, national reforms and improved data collection – particularly on unpaid care work – reflect a growing awareness of the economic and social value of care.

However, care systems across the region remain structurally underdeveloped, underfunded, and highly informal. Provision is largely focused within households and communities, with women and girls performing the majority of unpaid care work. Formal care services are limited, fragmented and unevenly distributed, while many paid care workers – particularly domestic and community workers – operate outside formal labour protections and social security systems.

Policy engagement with care is expanding but remains partial and indirect. Most regional and national frameworks address care through labour regulation, social protection systems, and development and gender equality agendas. As a result care is typically treated as a contextual factor shaping access to existing rights, rather than as a standalone, enforceable human right. While important advances are emerging, progress continues to be constrained by structural barriers, including underinvestment, informality, weak enforcement of labour protections and fragmented governance systems.

Asia-Pacific 

Across the Asia-Pacific region, demand for care is rising rapidly driven by an ageing population, urbanisation, migration and changing family and labour market structures. Despite this growing demand, care provision remains uneven and fragmented, and in many contexts heavily reliant on family labour. Women continue to carry the largest share of unpaid care responsibilities, while paid care work is highly feminised, undervalued, and often characterised by informality, low wages and weak labour protections. (UN Women Regional Office for Asia and the Pacific (2025)) [XLVI]

Distinct regional patterns in care regimes are evident. In East Asia, the state and market have historically played a more active role in care provision. Formal systems – particularly long-term care insurance systems and subsidy service models - have expanded access and contributed to the professionalisation and regulation of care. For example, Japan introduced a universal LTC insurance system in 2000, providing universal elder care services based on assessed need through a social insurance model funded by taxes and contributions. Similarly South Korea integrated LTC benefits into its national health insurance system in 2008. By contrast in much of South and Southeast Asia – family based caregiving remains the dominant model, with unpaid caregivers providing the majority of care. Formal services tend to play a supplementary role. Across the region, care systems are often constrained by limited public investment, a largely informal and low-paid workforce, and persistent social norms that reinforce women’s primary responsibility for caregiving.

Migrant labour is also a defining feature of several care systems. While migrant care workers are essential to sustaining care provision, they frequently face precarious working conditions, limited labour protections and restricted access to rights. At the same time, labour migration can exacerbate care deficits in countries of origin. This dynamic is particularly evident in the Pacific, where programmes such as the Pacific Labour Mobility Scheme facilitate the migration of nurses and care workers to countries including Australia and New Zealand, placing additional strain on domestic care systems.[XLVII]

A broader structural trend across the region is the expansion of market-based models of care provision. Privatisation has increased across multiple sectors, often resulting in mixed systems in which governments finance or subsidise care while relying on private providers to deliver services. In several countries, particularly those with rapidly ageing populations (Japan, South Korea, Thailand, China) this has been accompanied by increased investment in private healthcare and aged care services. In Pakistan, an accelerated wave of health system privatisation, including the outsourcing of public hospitals, has raised concerns about declining access to care.

International financial institutions have also shaped care-related policy trajectories by promoting market-oriented reforms and private sector participation. In some contexts, this has redirected public resources towards private provision rather than strengthening public systems. In India, for example, research suggests that public funding programmes linked to such reforms, particularly during the COVID-19 pandemic, have channelled resources into private healthcare delivery.(Engel 2021) [XLVIII]

These developments have been accompanied by labour deregulation. For example in India and Pakistan, labour law consolidation has reduced regulatory oversight and protections for workers.[XLIX] These dynamics pose significant challenges to the development of rights-based care systems, as weakened labour standards undermine both the quality of care and the conditions of care work.

Policy Context

Compared with other regions, Asia and the Pacific lack strong regional institutional frameworks that address, or have the potential to address, care through a rights-based lens. In contrast to Europe, the Americas or Africa, there is no regional human rights body with comparable authority or enforcement capacity. As a result, coordinated regional policy development on care remains limited, and most policy innovation occurs at national or subnational levels. This decentralised approach has contributed to significant variation across countries.

Existing regional frameworks acknowledge the importance of care, but generally stop short of establishing binding rights or enforceable obligations. Care is therefore recognised as a policy priority, but not codified as a legal entitlement.

Sub-regional engagement has emerged through the Association of Southeast Nations (ASEAN), including the ASEAN Comprehensive Framework on the Care Economy (2021) and the ASEAN Declaration on Strengthening the Care Economy (2024).[L] These initiatives represent important steps in elevating care within the regional policy discourse and highlight the economic and social value of unpaid care work, its centrality to gender equality and social wellbeing, and the importance of developing national care systems. They also begin to frame care as integral to human dignity and equality.

However, these frameworks remain largely normative and non-binding. Regional forums increasingly link care to gender equality, social inclusion and broader human rights outcomes, but enforcement mechanisms are absent. As a result, care continues to be addressed indirectly – primarily through labour law, social protection and health policy – rather than as an autonomous right. Policy responses tend to adopt sectoral approaches, with particular emphasis on childcare as a means of supporting women’s labour market participation and early childhood development, rather than building comprehensive care systems.

Emerging regional dialogues, such as the Asia-Pacific Care Forum, have further elevated care within policy debates, emphasising its role as a public good and the need for evidence-based policymaking and stronger labour protections.(UN Women Regional Office for Asia and the Pacific, 2025)[LI] At the same time, concerns have been raised regarding the growing role of private sector actors in shaping the care agenda, reflecting broader tensions within regional and international policy spaces, where the growing recognition of care has not always been matched by commitments to publicly funded, rights-based care systems.

Re-municipalisation of Care Services

While marketisation remains dominant, there have been targeted instances of services being brought back under public control, or of public investment being increased, often in response to concerns over quality, cost, or workforce conditions. These efforts tend to focus on insourcing specific services rather than fundamentally restructuring care systems. Examples include:

• New South Wales (2024): several local health districts have brought previously outsourced services, such as cleaning, catering and some care support roles, back in-house within aged care settings.

• Victoria (2025-present): 2025-2026 Victoria State Budget included financial commitments to public aged care sector, specifically aimed at improving existing infrastructure and funding new public facilities. It has also increased the number of publicly provided residential aged care beds, strengthening public sector involvement in [service](https://www.theweeklysource.com.au/vic-govt-opens-11m-per-bed-aged-care-home-at-hospital/#:~:text=The facility%2C renamed Leura Aged,aged care facilities across Victoria.) delivery.[LII]

• Japan (2000-present): under the Long-Term Care Insurance Act (1997, implemented 2000) municipalities retain responsibility for maintaining the stability of the LTC system. They are empowered to intervene directly or transfer service provision to non-profit actors where private systems fail.[LIII] As one of the world’s most highly digitalised economies, Japan has seen a rapid expansion in the ‘platformisation’ of health services - and increasingly care services – accompanied by a growing reliance on platform-based workers. While these developments offer potential gains in efficiency and access, they also introduce risks relating to the quality and continuity of care.

• New Zealand (2022): establishment of Health New Zealand (Te Whatu Ora) centralised control over health services, strengthening state oversight of care infrastructure and commissioning.[LIV]

These developments reflect a broader pattern of regulation and insourcing – focused on service functions and quality control – rather than full structural shift away from mixed or market-based systems.

Selected National-Level Reforms

Australia

Australia has undertaken significant policy reform in the care sector in recent years, particularly following the Royal Commission into Aged Care Quality and Safety, which documented widespread systemic failures in the aged care system linked in part to the marketisation and privatisation of care services. It identified persistent issues of inadequate regulation, poor quality of care and workforce pressures and recommended stronger oversight, alongside a fundamental redesign of the system. Central to its recommendations was the development of a new human-rights based legislative framework that would prioritise dignity, safety, autonomy and high-quality care. The recommendations have informed subsequent legislative reform.

The Aged Care Act, 2024 which came into force in November 2025, marks a major change to aged care. Replacing the 1997 legislation, the Act introduces a Statement of Rights and Statement of Principles, that places the rights, dignity, preferences and autonomy of older people at the centred of aged care. It establishes a support-based funding model and a right to palliative and end of life care. It is complemented by the Aged Care Quality Standards which require providers to deliver safe, person-centred care and comply with governance and accountability requirements.[LV]

Taken together, these reforms signal a move towards a more rights-oriented framework, linking service delivery, provide accountability and workforce responsibilities. Care workers are explicitly recognised as central to the realisation of care recipients’ rights. However, while the framework embeds key human rights principles – such as dignity, autonomy, equality and accountability - it does not establish a broader universal right to care in law. Instead, rights are operationalised within the regulation and delivery of aged care services.

Since 2025, implementation has centred on rolling out the new Support at Home programme, revised funding and co-contribution arrangements, and a new integrated assessments system. However, there are implementation challenges, including higher user costs, assessment bottlenecks, and ongoing capacity constraints, highlighting the tensions between rights-based reform objectives and practical implementation.

Beyond aged care, Australia has pursued a range of complementary policy initiatives across care:

• Early childhood education and care: the government has committed to expanding access to universal childcare, including moves towards a national universal childcare system, alongside proposed legislative requirements for private providers to disclose detailed financial and operational data (wage structures, costs, pricing) to inform future system design. Ongoing research into wages, provider conditions and family experiences will shape future reforms.[LVI]

• National Carer Strategy (2024): a 10-year framework to improve the wellbeing, recognition and financial security of unpaid carers, while supporting their participation in education and employment. It explicitly recognises unpaid care as essential to both social and economic life and emphasises the rights and dignity of carers.[LVII]

• National Disability Insurance Scheme (NDIS): originally introduced in 2013 and amended in 2024-25, it provides personalised public funding to enable people with disabilities to access home and community care services, although most services are delivered by private providers.[LVIII]

• Draft National Strategy for Care and Support Economy: an emerging framework seeking to address gender pay gaps, improve job quality for care workers, and develop more integrated approaches across care sectors.[LIX] While significant in scope, it does not anchor reforms in an explicit right to care.

Recent reforms demonstrate meaningful progress towards embedding rights-based principles within care systems, particularly in aged care. However, they remain bounded within regulatory and programmatic frameworks. Care in Australia is not recognised as an enforceable, human right and combined with continued reliance on private service delivery, care remains only partially articulated in rights-framing and more through social protection, labour market participation or service delivery systems.

Philippines

In the Philippines, care policy is evolving though a combination of labour recognition and local level innovations. At the national level, Barangay Health Workers - who are central to primary healthcare delivery in local communities - have secured partial legal recognition under the Magna Carta of Public Health Workers.[LX] Following sustained advocacy by worker organisations, an omnibus legislative bill is currently under discussion to further strengthen their employment status, including expanded access to social protection and improved working conditions. While these developments represent progress in recognising community health workers as part of the public health workforce, many workers continue to face low and irregular pay, as well as limited labour protections.

The Philippines is also advancing a National Action Plan on the Care Economy, signalling a growing commitment to integrating care into national development planning. At the subnational level, as of March 2021, at least 28 local governments had enacted ordinances addressing unpaid care work, allocating funding through Gender and Development budgets to support care-related services. Municipalities such as those in Eastern Samar have introduced local care policies aimed at recognising, reducing, and redistributing unpaid care work.

While these initiatives align with broader goals of gender equality, social protection, and labour participation, care is not yet codified as an autonomous human right in national law. Instead, current reforms reflect an emerging policy approach, with civil society continuing to advocate for a stronger state role in building comprehensive public care systems. (UN Women Regional Office for Asia and the Pacific, 2025)[LXI]

Indonesia

Indonesia has launched a Roadmap on the Care Economy (2025–2045) in collaboration with the ILO and other partners. The roadmap seeks to integrate care into long-term national development planning, aligning with international labour standards and gender equality frameworks. Key priorities include strengthening labour protections for care workers, expanding access to care services, and recognising care as a central component of economic and social policy. While this represents a significant step in elevating care within national policy debates, care continues to be framed primarily as a development and employment issue, rather than as a constitutionally or statutorily protected right.[LXII]

Malaysia

Malaysia has launched a National Care Strategic Framework and Action Plan (2026–2030)[LXIII] aimed at strengthening care systems through governance reform, workforce development, and expanded care infrastructure. The framework situates care within broader agendas of social inclusion, economic participation, and equitable service provision. At the subnational level, Selangor State adopted a comprehensive ‘care economy’ policy in 2024 covering childcare, elder care, and wider care responsibilities. While these developments reflect growing institutional attention to care, they do not yet establish a legally enforceable right to care.[LXIV]

India

In India, care policy is characterised by a divergence between local innovation and broader structural constraints. Some states have introduced social protection measures recognising caregivers, including carer allowances in Karnataka and Delhi which acknowledge the economic contribution of unpaid care and provide financial support.[LXV] Civil society organisations have also formed national alliances advocating for the inclusion of caregivers within pension, health, and social protection systems.

At the same time, national-level labour reforms have consolidated labour laws and, in some cases, weakened regulatory protections. While there has been some expansion of public health provision—such as urban health posts staffed primarily by nurses—broader trends towards privatisation and labour deregulation continue to constrain progress towards more robust, rights-based care systems. Notably, the state of Kerala has taken a more integrated approach, embedding care within social protection frameworks with a focus on elder care, working conditions, and alignment with national and international commitments.[LXVI]

Thailand

Thailand is moving towards a care system model combining universal health-based services with community care and gradual workforce transformation, although has not yet transitioned to a comprehensive rights-based care framework. These reforms have included using public health budgets to expand the community-based care workforce, formalising care employment and integrating informal workers into social security systems, as well as integrating LTC within its universal health coverage systems. Labour law reforms have also strengthened care-related employment conditions for maternity and paternity leave.

Other national-level initiatives:

• Nepal: Progress has been made in extending social protection to informal economy workers including community health workers. The government has also expressed commitment to developing a national care law covering childcare, elder care, and health services, with a focus on improving working conditions.[LXVII]

• Maldives: With the recent establishment of industrial relations laws, the health sector is negotiating one of the country’s first collective agreements.

• Japan: Ongoing reforms to the long-term care system include strengthened financial transparency requirements for providers, investment in digital health infrastructure, and expansion of home-based care, within a universal social insurance framework.

• South Korea: Parental leave policies have been expanded to encourage more equal sharing of caregiving responsibilities between parents.[LXVIII]

• Pakistan: A ‘Transform Care Forum’ held in September 2025 brought together government, employers, and civil society to develop pathways for care reform, reflecting growing efforts to integrate care into national development strategies.

• Sri Lanka: Launched a pilot study to explore the correlation between gender pay gaps and care responsibilities.[LXIX]

• Fiji: National Action Plan (2023-2038) to prevent violence against women and girls highlights the importance of the 5Rs framework, linking care systems to broader gender-based violence prevention strategies.[LXX]

Summary

Across Asia and the Pacific, care is gaining increasing prominence within policy agendas, particularly in relation to health systems, social protection, labour regulation, and local governance initiatives. In several countries, care is being recognised as essential social infrastructure linked to dignity, gender equality, and economic participation.

However, progress remains uneven across the region and constrained by structural factors, including reliance on unpaid family care, the feminisation and informality of the care workforce, growing dependence on migrant labour, and the expansion of market-based service provision.

While references to human rights are increasingly present in policy discourse, care is still largely framed through sectoral and instrumental approaches—particularly in relation to labour markets, social protection, and development planning—rather than as an explicit, enforceable right.

The absence of strong regional governance frameworks and binding legal standards further reinforces this challenge, leaving care policy largely shaped at the national level. As a result, progress remains dependent on levels of public investment, labour protections, and the balance between public and private provision. This creates ongoing tensions between emerging rights-oriented policy aspirations and the realities of implementation within mixed and often marketized care systems.

Middle East and North Africa (MENA) 

Care Systems & Trends

Across the Middle East and North Africa (MENA), care provision remains predominantly organised around family-based arrangements, with limited public investment in childcare, eldercare, disability support, and long-term care infrastructure. Care responsibilities are deeply shaped by gender norms and legal frameworks that position caregiving as women’s unpaid duty within the household. Family laws governing marriage, divorce, custody, and inheritance often reinforce this arrangement by treating care as a private family responsibility rather than a collective social obligation. In this way, care is embedded within legal systems in forms that institutionalise women’s duty to provide care without recognising its economic or social value. As a result, unpaid care work is rarely recognised as an economic contribution or reflecting into systems of compensation, property rights or social protection. Women therefore perform the majority of unpaid care work across the region, contributing to low female labour-force participation rates and persistent gender inequalities.

Where formal care policies exist, they are generally embedded within labour law, social protection, or health systems, rather than framed as an explicit right to care. Many countries provide statutory maternity leave and workplace protections for women workers, and some governments have expanded childcare services and early childhood education programmes to support women’s labour-market participation. However, these measures are typically confined to the formal sector and do not address the broader needs of unpaid caregivers, informal workers, or care recipients.

Domestic work is a central pillar of care systems in several MENA countries, particularly higher-income states, where migrant domestic workers provide a substantial share of childcare, eldercare, and household services. While some governments have introduced legal reforms to regulate domestic work, many workers remain subject to separate labour regimes with weaker protections, often under sponsorship systems that increase vulnerability to exploitation and abuse.

More broadly, labour laws in parts of the region have historically penalised caregiving through practices such as pregnancy-based dismissal, discrimination against women of childbearing age, and weak workplace protections for pregnant workers. Although reforms have been introduced in some contexts, care continues to be treated largely as a private productivity constraint affecting women’s labour market participation, rather than as a social right that requires comprehensive policy frameworks.

Care systems across the region are also shaped by privatisation, institutionalisation, and weak regulatory oversight. Residential institutions for older persons, people with disabilities, and children are widespread and often operated by private or faith-based organisations, sometimes with limited accountability mechanisms. In recent years, market-based provision of care services—particularly in eldercare and private healthcare—has expanded, often creating systems that are inaccessible or unaffordable for lower-income households. At the same time, migrant domestic workers and low-paid local care workers dominate the sector and occupy the lowest tiers of the labour hierarchy, frequently facing precarious employment conditions, limited labour protections, and unsafe working conditions.

In addition, several countries – including Egypt, Jordan and Morocco – have expanded public-private partnerships in childcare provision, often with support from international financial institutions. While such arrangements may increase service availability, they also risk weakening the role of the public sector in guaranteeing accessible, affordable and quality care, particularly for lower-income households.

Policy Context

Policy attention to care is gradually increasing, but it remains narrow in scope and often disconnected from the wider realities of informal economy work and unpaid care labour. Existing initiatives tend to focus primarily on formal-sector childcare provision, designed to facilitate women’s participation in the labour market. While these policies expand access to childcare services for some workers and represent a recognition that care requires public intervention, they do not address the full spectrum of care needs, nor do they adequately support unpaid caregivers or workers in informal employment, who make up a substantial share of the workforce in many countries.

No country in the region currently has a comprehensive, rights-based care framework. Instead, policy responses generally follow a logic in which governments acknowledge that care responsibilities constrain women’s economic participation and respond by providing limited, targeted services – primarily childcare during working hours. This approach leaves broader structural issues unaddressed, including unpaid care burdens, labour informality and unequal access to services.

Nonetheless, some national-level initiatives indicate incremental progress:

• Tunisia has explored expanding public childcare and eldercare services to boost female labour force participation, and has begun integrating care into labour and gender equality frameworks.[LXXI]

• Jordan has promoted policy discussions on recognising and redistributing unpaid care work as part of efforts to increase women’s labour-market participation.[LXXII] Labour law reform debates (2024-2025) have included provisions on workplace childcare facilities and expanded parental protections, building on earlier requirements for employer-provided childcare under certain conditions.

• Egypt has expanded social protection programmes that provide income support to low-income families, older persons, and people with disabilities, including cash-transfer programmes, indirectly supporting caregiving needs.[LXXIII] Policy discussions linked to employment and social protection strategies have also included proposals to expand childcare and strengthen maternity protections, though implementation remains uneven and largely limited to the formal sector.

• In Lebanon, legislative proposals have been introduced to regulate childcare services and explore flexible work arrangements for workers with caregiving responsibilities.[LXXIV]

• Kuwait has implemented publicly funded home-based care services for older persons as part of its National Strategy for Older Adults Health Service.[LXXV]

• Morocco has advanced its universal social protection reform programme (2021-2025), including expanded health insurance and family allowances. While these measures may help to reduce care burdens, they do not directly recognise or remunerate care work itself.

While these initiatives represent important steps, their reach remains limited and uneven. They primarily target workers in formal employment and continue to frame care in terms of labour productivity, workplace flexibility, and women’s employment, leaving informal workers and unpaid caregivers largely outside policy protection. Implementation gaps are also significant. Weak enforcement, limited funding, and political instability often undermine the effectiveness of existing measures. Even where regulatory frameworks exist, they are inconsistently applied and may be shaped by broader political or religious dynamics.

Summary

Across the MENA region, care continues to be conceptualised primarily as a private family responsibility and a constraint on women’s economic participation, rather than as a public good or a human right. This framing limits both the scale of public investment and the development of comprehensive care systems.

North America

Across North America, care policy is shaped by multi-level governance and a long reliance on market based service delivery. In both Canada and the United States, responsibility for care is distributed across federal, provincial, state, and local governments, resulting in fragmented systems with uneven access, regulation, and quality. Care has historically been treated as a private household responsibility, supplemented by targeted public programmes rather than organised as a universal public service. This has contributed to high costs, limited availability, uneven service quality, a heavy reliance on women’s unpaid labour, and chronic workforce shortages.

Care systems across the region operate through a hybrid model combining family responsibility, market provision, and fragmented public subsidies. Policy frameworks tend to address care through labour standards, affordability measures, social protection, and support for women’s labour-force participation, rather than through universality, dignity, or enforceable rights. In the United States, in particular, care remains highly market-driven, relying heavily on private providers, employer-linked benefits, insurance schemes, and state-level initiatives – resulting in deeply unequal access shaped by income, employment status, and geography.

Privatisation remains a defining feature of North American care systems. Services have long been organised through private providers, households, and fragmented public subsidies rather than through universal public provision.

In Canada, recent childcare reforms have attempted to shift away from a predominantly market-based model by prioritising public and non-profit expansion. However, private and for-profit providers continue to play a substantial role, particularly in areas not adequately served by public provision. While some provinces have introduced limits on for-profit expansion, there is growing concern that insufficient public funding, long waitlists, and political pressures could push governments back toward deregulated, market-oriented approaches. Publicly delivered and municipally operated childcare services demonstrate stronger outcomes in wages, retention, funding stability, and accountability, but remain unevenly distributed.

In long-term care and home care, private provision remains significant. Publicly funded services are frequently supplemented - or replaced - by private facilities, agency staffing, and out-of-pocket payments, producing access inequalities based on geography and household resources. The COVID-19 pandemic exposed severe failures in some privately-operated long-term care facilities, particularly in Quebec and Ontario, but private operators remain deeply embedded in the system.

On the contrary, Quebec province remains a strong North American example of publicly supported childcare through its low-fee, publicly funded and largely non-profit childcare system. At the same time, the system has come under mounting pressure from staffing shortages, budget constraints, long waiting lists, and the expansion of subsidised private providers. In health and long-term care, recent structural reforms have raised concerns that public and private providers are increasingly being placed on an equal footing, potentially accelerating privatisation within publicly funded systems. Trade unions and civil society organisations have warned that such developments risk entrenching market logics in care provision. In Quebec, proposals to provide payments to close unpaid caregivers for family-provided care have been criticised for shifting responsibility for care from public systems to households. While framed as support for families, such measures risk reinforcing women’s unpaid caregiving roles in the absence of adequately funded public services.

In the United States, privatisation is even more deeply entrenched. Care provision relies heavily on employer-linked benefits, private insurance, for-profit providers, and household payments. Access is closely tied to employment status, income, insurance coverage, and state of residence. This structure produces profound inequalities and leaves many families dependent on low-paid private care work or unpaid family labour.

Across the region, privatisation has shaped service delivery and labour conditions. Care workers frequently face low wages, weak benefits, precarious contracts, understaffing, and inadequate occupational health and safety protections. Migrant workers are particularly vulnerable, especially where immigration regimes tie workers to a single employer. This has contributed to both unequal access for care recipients and deteriorating conditions for the workforce.

Re-municipalisation of Care Services

There are emerging, though limited, examples in Canada of care services being brought back under public control or delivered more directly through public institutions.

In childcare, some provinces and municipalities have expanded public delivery through school boards, municipalities, and other public bodies.

• In British Columbia, new legislation announced in 2025 aims to expand before- and after-school care and school-based childcare centres by enabling school districts to provide, operate, or directly facilitate childcare services on school grounds for children aged 0–12.[LXXVI]

• In Manitoba, the province is expanding licensed childcare spaces through projects linked to major health facilities, including hospital-based childcare for health-care workers to make use of existing public infrastructure.[LXXVII]

In long-term care, public intervention has often occurred in response to crisis or private system failure. During and after the COVID-19 pandemic, several provinces temporarily assumed control of privately operated long-term care homes because of staffing shortages, severe outbreaks, or catastrophic neglect.

• In Quebec, the privately run CHSLD Herron facility in Dorval was effectively taken over by the provincial health system in 2020 following widely reported failures in care.[LXXVIII]

• In Alberta **and **British Columbia, public health authorities stepped in to operate homes owned by financially unstable private investors when safety and staffing collapsed.

Although these interventions were framed primarily as emergency management measures rather than structural reform, they established an important precedent that where private provision fails, the state may be compelled to resume operational control in order to protect residents and maintain services.

There are also some examples of service-level insourcing. In Vancouver, food services at Oak Care Centre, a publicly run facility whose food operations had been outsourced since 2003, were brought back in-house in 2024 by the public health authority. This illustrates a narrower form of re-municipalisation focused on quality control, and workforce conditions.[LXXIX]

Policy Context

Canada

Canada has undergone the most significant recent care policy shift in North America, particularly in early childhood education and care. Historically, childcare was treated largely as a private market service, characterised by high fees, limited access, weak coordination, and strong reliance on private providers, with major variation across provinces. This began to change in 2021 with the launch of the federal Early Learning and Child Care (ELCC) programme, supported by substantial public investment and bilateral agreements with provinces and territories.

The shift was consolidated through the Canada Early Learning and Child Care Act (Bill C-35) which received Royal Assent in 2024. The Act formalised a federal commitment to a Canada-wide childcare system based on affordability, accessibility, inclusivity, and quality, and signalled a move toward treating childcare as essential social infrastructure rather than a private commodity.[LXXX]

The federal framework provides funding to provinces and territories in exchange for commitments to expand childcare spaces, reduce fees, and improve workforce conditions, while expressing a clear policy preference for public and non-profit provision over for-profit expansion. A central objective has been to reduce fees to an average of $10 per day. However, implementation has been uneven, with provinces adopting different delivery models and degrees of reliance on public versus mixed provision. Crucially, the reforms stop short of establishing a legally enforceable right to childcare, leaving the system vulnerable to political and fiscal shifts.

Significant structural challenges persist. Waitlists remain long, access is highly unequal – particularly in rural and remote areas – and workforce shortages are acute. Early childhood educators are often underpaid, lack adequate benefits and pensions, and face difficult working conditions that contribute to high turnover. In many cases, affordability gains have outpaced workforce development, further straining system capacity. Migrant workers also play a significant role across care sectors and are frequently exposed to precarious employment conditions linked to immigration status.

The initial federal-provincial agreements were five-year arrangements and are now being renewed amid ongoing concerns about insufficient funding, shortages of spaces, and long waitlists. Some provinces have opted only for short-term renewals, and there is growing debate over whether governments may retreat from long-term system-building toward more income-tested or market-compatible approaches. Canada has therefore moved significantly closer to treating childcare as a public good, but it has not yet established a direct legal entitlement to childcare services.

Beyond childcare, long-term care, home care, and disability support remain less developed as universal public systems. Access is often delayed by capacity constraints, pushing families towards private provision. Consequently, care is frequently experienced not as a guaranteed right, but as a fragmented and conditional set of services.

Long-term care reform has been shaped largely by the post-pandemic response. Federal initiatives include national long-term care standards and consultations on a proposed Safe Long-Term Care Act to set national principles for safety, quality, and accountability. As long-term care is primarily a provincial responsibility, these federal initiatives function mainly as frameworks linked to funding rather than as directly enforceable law. The most substantial binding reforms have therefore taken place at the provincial level.

In Ontario, the Fixing Long-Term Care Act (2021) introduced stronger inspection and compliance mechanisms, a target of four hours of direct care per resident, and workforce investments. Other provinces, including British Columbia and Quebec, have also pursued similar reforms focused on staffing, regulation and expanding home- and community-based care.

Additional measures, such as the Disability Benefit Act (Bill C-22) (2023) created a new disability income benefit to provide income support, although does not establish a right to care.

Quebec

Quebec remains the most developed example of publicly supported childcare in North America. Since the late 1990s, its low-fee system centred on Centres de la petite enfance (CPEs), publicly funded and largely non-profit centres, has demonstrated the potential of public childcare to increase women’s labour force participation, reduce costs, and generate broader socio-economic benefits.

However, the system faces increasing strain. Persistent waiting lists, staffing shortages, fiscal pressures, and the growth of parallel private provision have introduced uneven quality and access. In long-term care and home care, limited public capacity continues to push families towards private options.

Recent healthcare restructuring has intensified concerns about privatisation. The creation of a central coordinating agency in 2024, alongside reforms that critics argue place public and private providers on more equal terms, has prompted warnings from unions and civil society that market dynamics may become further embedded within publicly funded systems.

United States

In the United States, federal engagement with care has expanded in recent years through targeted funding, strategic initiatives, and programme reforms. Notable measures include the American Rescue Plan Act (2021), which provided temporary stabilisation funding for childcare, the National Strategy to Support Family Caregivers (2022) and expanded support for Medicaid Home and Community-Based Services.

Some city-level initiatives have also been developed. In late 2025 and early 2026, the New York Council, Mayor and Governor outlined plans to expand early care and education, building on existing universal prekindergarten and childcare initiatives. The proposals include extending access across multiple age groups, including a phased introduction of a ‘2-Care’ programme to provide free preschool for two year olds, initially in New York City, and continued expansion of ‘3-K’ (three year old childcare provision).[LXXXI]

In March 2026, New York City also announced its first free, on-site childcare pilot programme for municipal workers. Applications opened in April 2026, with the programme scheduled to begin later in the year following completion of a purpose-built facility. The centre will provide services for approximately 40 children aged six weeks to three years, offering year round care (Monday-Friday, 8am-6pm). The initiative involves the development of a purpose-build childcare facility. As a test case for broader childcare expansion, the pilot represents an initial step toward the administration’s broader objective of delivering universal, accessible childcare.[LXXXII]

Despite these developments, the US care system remains structurally fragmented and predominantly market-driven. Recent initiatives have largely been time-limited or targeted expansions rather than establishing a broader statutory right to care. Provision continues to rely heavily on a mix of private markets, employer-linked benefits and city and state-level policy variation. Consequently, while recent reforms have improved funding and access at the margins, they have not fundamentally transformed the system. Access to care remains uneven, stratified by income, employment status and geography, with persistent systemic inequalities.

Summary

Canada has moved further than the United States toward framing care—particularly childcare—as a public good and a component of national social infrastructure. Federal reforms, combined with Quebec’s longstanding model, have laid the groundwork for a more coordinated and publicly supported system. However, this shift remains incomplete.

Across North America, care systems remain fragmented, under-resourced in key sectors, and heavily reliant on private provision and unpaid family labour, with women bearing the majority of caregiving responsibilities. Workforce shortages, precarious employment conditions, and unequal access to services persist across both countries.

Critically, these developments have not been accompanied by the legal recognition of a universal right to care. Policy debates – especially in Canada - continue to focus on affordability and system expansion rather than enforceable entitlement. Consequently, despite meaningful progress, care has yet to be firmly established as an enforceable social right across the region.

Caribbean

Care Systems & Trends 

Across the Caribbean, care is typically addressed within broader social protection, welfare, health, education and family policy frameworks rather than through comprehensive, system-wide care strategies. Responsibility for care remains predominantly family-based, with households and communities providing the majority of childcare, eldercare, and support for persons with disabilities. Public care infrastructure is limited, while demand for services is rising due to population ageing, urbanisation, migration, and the persistent gendered division of unpaid care work.

Unpaid care labour—performed primarily by women – remains central role to the functioning of households and communities, yet is largely invisible in economic statistics and policy design. This unequal distribution contributes to significant time poverty among women, constraining their access to paid employment, education, and civic participation, and reinforcing broader labour market inequalities.

Care provision spans multiple groups and institutional settings. Early childhood care and education is delivered through a combination of public preschool systems, state-supported childcare facilities, and private providers, but demand for affordable childcare significantly exceeds supply in many countries. Children considered at risk are often placed in institutional care under welfare or justice systems. Eldercare is emerging as a growing pressure point with a rising demand for long-term support. In several countries, older persons without family support are cared for through state hospitals, geriatric institutions, district hospitals, or limited home-help programmes. Care and support for persons with disabilities also remains uneven and fragmented across health, education, and welfare systems, with accessibility often falling short of formal legal commitments.

While formal care services exist, their availability is generally limited and often unaffordable. Public investment on care infrastructure is constrained by the fiscal pressures facing many Caribbean economies, while staffing shortages, fragmented training systems, and weak regulatory oversight undermine service quality and accessibility. Private and faith-based providers play a significant role in service delivery - particularly in childcare, residential care, and community welfare services – but this mixed model produces uneven standards and reinforces inequality.

Employment conditions in the care sector vary widely. Public sector workers are more likely to be unionised and covered by collective agreements. In contrast, workers in private, faith-based, and community settings often face lower wages, precarious contracts, weaker social protection and limited access to collective bargaining. In countries such as Jamaica and Barbados, trained care and social work professionals are frequently employed on short-term or donor-based contracts, with little long-term security. Domestic workers and home-based carers are especially vulnerable, often working informally or under weakly protected labour arrangements. Overall, there is clear evidence of increasing casualisation and partial privatisation of care work across the region.

Regulatory frameworks tend to prioritise public health, safety, and facility standards, but enforcement is often inconsistent. Inspection bodies are under-resourced, training requirements vary across sectors, institutional coordination is weak, and professional development pathways remain poorly defined. As a result, many facilities operate with insufficiently trained staff and inconsistent oversight.

Taken together, Caribbean care systems are characterised by limited public infrastructure, heavy reliance on unpaid family care, uneven service provision, fragmented institutional responsibility, and growing demographic and economic pressures.

Policy Context

Across the Caribbean, care has historically been associated with state responsibility through welfare, public health, and education systems. However it has largely been framed as a form of social assistance or poor relief rather than as a universal entitlement. This framing continues to shape policy design and public attitudes. Public care services are often stigmatised, middle-income households may be criticised for accessing subsidised childcare or welfare-based supports, and higher-income families are generally expected to meet care needs privately. These dynamics undermine support for universal care systems and reinforce existing inequalities.

At the same time, the role of the state in care provision has diminished in many countries due to chronic underfunding, privatisation, austerity, and fragmented service delivery. In practice, care policy operates primarily through targeted welfare programmes rather than universal systems, resulting in uneven access and continued reliance on informal arrangements or private providers.

Recent institutional reforms in some countries have also been shaped by international financial institutions such as the IMF, World Bank, and Inter-American Development Bank. These reforms have encouraged public sector rationalisation administrative consolidation and workforce reduction for efficiency purposes. However, such reforms tend not to address underlying problems related to staffing, training, or service quality.

At the regional level, there is growing recognition of the importance of care within development and equality agendas. CARICOM (Caribbean Community) undertakes regional cooperation in health and social policy, although implementation remains uneven. The CARICOM Gender Equality Strategy and Action Plan (2020–2025) has been important in raising the profile of unpaid care work, the redistribution of care responsibilities, and the need to strengthen social protection systems for unpaid caregivers. Such regional frameworks increasingly use language associated with dignity, equality, and inclusion, but remain primarily normative and policy-oriented rather than legally binding.

Several structural constraints shape the regional policy environment. Public financing remains limited and uneven, reflecting the small size and high debt burdens of many Caribbean economies. Institutional coordination is weak, with responsibility for care spread across multiple ministries and agencies. Time-use data and other evidence needed for effective care planning remain limited in many countries. Few states provide comprehensive paid paternity or parental leave, which reduces incentives for shared caregiving and reinforces gendered inequalities in unpaid work. Meanwhile, large parts of the paid care workforce—particularly domestic work and home-based care—are informal or are dominated by migrant work, experiencing weak legal protection, limited social security coverage, and uneven enforcement.

Despite growing recognition of the social and economic importance of care, care as a human right remains only weakly articulated in Caribbean legal and policy frameworks. Policy debates continue to prioritise service delivery, social protection reform, or labour market inclusion rather than universal entitlements to care services or strong labour rights for care workers. As a result, care remains primarily framed as a welfare issue rather than a universal social right.

National-Level Reforms

Barbados

Barbados has undertaken some of the most visible recent care-related reforms in the region, particularly in childcare, family leave, and social protection administration. At the same time, the country faces increasing pressure on its care systems, especially in childcare and eldercare. Public childcare centres are operating at or near capacity, waiting lists are long, and private childcare services are unaffordable for many low- and middle-income households.[LXXXIII] These constraints disproportionately affect women, who continue to carry the majority of unpaid caregiving responsibilities and often reduce working hours, enter informal employment, or withdraw from the labour market as a result.[LXXXIV]

A key recent reform is the Family Leave Bill, 2025, which replaces the earlier maternity leave framework with a more gender-inclusive system. [LXXXV] The legislation extends maternity leave, introduces statutory paternity leave for the first time, strengthens workplace protections against dismissal related to pregnancy or parental leave, guarantees reinstatement, and integrates parental benefits into the National Insurance and Social Security system.[LXXXVI] This is a significant development within the Caribbean context, particularly because it recognises that both parents should have access to leave for early childcare and family bonding. However, the reform remains rooted primarily in labour market entitlements and formal employment relationships, rather than establishing a broader right to care services. Informal workers remain largely excluded.[LXXXVII]

Barbados has also undertaken significant institutional restructuring through the creation of the Social Empowerment Agency (SEA), launched in January 2026. The SEA consolidates several previously separate institutions, including the Child Care Board, National Assistance Board, Welfare Department, National Disabilities Unit, and the Resilience and Reintegration Unit, into a single body responsible for coordinating social assistance and support services. The reform is intended to address longstanding fragmentation by creating a more integrated, ‘one-stop’ model for accessing services such as child protection, disability support, and welfare assistance. While this strengthens the administrative architecture of social protection and is framed in terms of dignity, empowerment, and social inclusion, it does not create enforceable rights to care or universal entitlements.[LXXXVIII]

Another important initiative is the government’s plan to introduce universal nursery access for all three- and four-year-old children from September 2026 as part of a wider education reform agenda.[LXXXIX] This signals a move toward treating early childhood education more like a universal service, but implementation will depend on expanded infrastructure, staffing, and sustained public funding. The government has acknowledged that demand may outstrip supply.[XC]

Barbados has also begun measuring unpaid domestic and care work for the first time, representing an important step in recognising the value of unpaid care within public policy. In addition, draft ageing and disability policies have emphasised dignity, access to care, and gender equality, although still remain under development.

Jamaica

In Jamaica, care policy has gained increasing attention within gender equality, social protection, and labour market frameworks, particularly in relation to the impact of unpaid care work on women’s economic participation. National policy discussions increasingly acknowledge caregiving as a barrier to women’s access to paid work and recognise the economic significance of unpaid care and domestic labour as a substantial share of GDP.[XCI]

The care system remains fragmented operating through a mix of public, private, faith-based, and non-governmental provision. While this diversity expands service availability, it also contributes to uneven standards, regulatory gaps, and limited coordination. Care workers frequently experience precarious employment conditions and limited representation in policymaking processes. [XCII]

Eldercare demand is also rising as the population ages. Long-term care services remain limited and fragmented, with support provided through a combination of public institutions, private facilities, faith-based organisations, and community providers. Government interventions focus largely on social assistance for economically vulnerable older persons, while families – primarily women - continue to provide most care.[XCIII]

The National Policy for Senior Citizens (2021) represents a key strategic framework, promoting active ageing and outlining priorities such as income security, healthcare and long-term care, social participation, and protection from abuse.[XCIV] However, it remains programmatic rather than legally enforceable, and comprehensive rights-based legislation is still under development. Jamaica’s National Social Protection Strategy and gender policy acknowledge unpaid care as a barrier to women’s economic participation, but they do not establish a legal right to care.

Across the region, several other initiatives reflect growing policy attention to care:

• Trinidad and Tobago has introduced a range of social welfare programmes supporting caregivers and legislative measures recognising the economic and social contributions of unpaid domestic work. However, support remains primarily benefits-based, rather than centred on universal service provision.[XCV]

• The Dominican Republic has taken steps toward more structured care policy development through the introduction of a National Care Strategy for older persons. The strategy incorporates human rights principles, such as dignity and social inclusion.[XCVI]

Summary

Across the Caribbean, policy attention to care is gradually increasing, particularly in childcare, ageing, disability support, and recognition of unpaid care work. These developments reflect a growing awareness of the social and economic importance of care, including its links to gender equality, labour market participation, and demographic change.

However, reforms remain largely fragmented, sector-specific, and unevenly implemented. Care systems continue to be characterised by limited public infrastructure, heavy reliance on unpaid family care, and a significant role for private and faith-based providers. Structural constraints—including underfunding, weak institutional coordination, workforce shortages, and limited regulatory capacity—continue to restrict service availability, affordability, and quality.

Although policy discourse increasingly incorporates concepts such as dignity, equality, and inclusion, care has not been established as a universal or legally enforceable right. Instead, it remains primarily framed within social protection and welfare systems, reinforcing unequal access and the stigmatisation of public provision. As a result, despite emerging reforms and growing recognition, care systems in the Caribbean remain underdeveloped and only partially integrated into broader social and economic policy frameworks.

4. Conclusions 

Care is now widely recognised as foundational to social reproduction, economic functioning, and human wellbeing. Yet across most regions, it remains structurally marginalised in law and policy. With few exceptions, care continues to be treated as an issue embedded within labour markets, social protection systems, or welfare provision—rather than as a universal, enforceable human right grounded in dignity and equality.

This structural gap produces consistent systemic outcomes, including a continued over-reliance on unpaid care work performed by women; fragmented governance across sectors and institutions; the expansion of marketisation and privatisation in care provision; and persistent precarity in care work, characterised by low wages, informality, and weak labour protections. At the same time, access to care remains deeply unequal, determined more by income, employment status, and geography rather than need.

Recent policy developments— including national care strategies, long-term care insurance models, childcare expansion, and recognition of unpaid care—represent important steps forward. There are also some examples of re-municipalisation and strengthened public provision, particularly in parts of Europe, as well as developments in Australia and Canada. However, these reforms remain largely programmatic and conditional. They do not fundamentally alter the legal status of care, nor have they established binding state obligations to ensure universal access, quality, and equity.

Across regions, care systems are gaining visibility but remain unevenly developed and rarely grounded in enforceable rights-based frameworks. While institutional approaches differ, a common pattern is that care is recognised as socially and economically essential, yet continues to be governed through fragmented, sector-specific policies rather than universal entitlements.

• In Europe, care systems are comparatively advanced, supported by regional frameworks such as the EU Care Strategy and Work-Life Balance Directive. These have strengthened coordination, labour protections, and service expansion. However, increasing marketisation and mixed public-private delivery models have introduced new forms of inequality, and care remains framed as a social service or insurable risk rather than a legal right.

• Across Africa, care provision remains highly informal and under-resourced, with the majority delivered within households and communities. Policy attention is growing—particularly around unpaid care, labour rights, and social protection—but care continues to be addressed indirectly. Emerging initiatives, including Kenya’s care policy framework and regional efforts on informal economy protections signal progress, though care is not yet recognised as an autonomous right.

• In the Asia-Pacific, care systems are diverse, ranging from more institutionalised models linked to health and social insurance, to predominantly family-based systems. While some countries have introduced reforms incorporating rights-based principles, care is still largely framed through development, labour market, or welfare lenses. Informality, low wages, and reliance on unpaid family care remain defining features across much of the region.

• In the Middle East and North Africa (MENA), care continues to be structured primarily as a private family responsibility, reinforced by gender norms and legal frameworks. Public provision is limited, and existing policies focus mainly on childcare and labour market participation. Migrant domestic workers play a central role but often face weak protections. Care is not recognised as a right in any country in the region.

• In North America, care systems are highly fragmented and market-driven. While Canada has made notable progress in developing a publicly supported childcare system, and some reforms in the United States have expanded family leave, access remains uneven and tied to income and employment. Care is not established as a universal legal entitlement.

• Across the Caribbean, care policy is embedded within social protection and welfare systems, with heavy reliance on unpaid family care and limited public infrastructure. Recent reforms indicate increasing policy attention - particularly in childcare, ageing, and caregiver support - but systems remain fragmented and care is not recognised as a universal right.

Despite regional variation, several common trends are evident. These include increasing recognition of care as essential social infrastructure, greater visibility of unpaid care work, growing policy attention to caregivers, and incremental improvements in labour protections for care workers, including those in informal employment. Some countries also retain elements of universal care models, though these are often historical rather than newly established. Overall, while these trends point toward a gradual shift in how care is understood, they fall short of establishing comprehensive, rights-based care systems.

The 2025 advisory opinion of the Inter-American Court of Human Rights marks a decisive turning point. By recognising care as an autonomous human right it establishes a clear normative and legal standard - care is not a policy option, but a state obligation. This provides a concrete foundation for advancing rights-based care systems globally and provides a strategic entry point for coordinated advocacy, legal reform, and institutional transformation.

Looking ahead, what is required is a systemic shift - from fragmented, market-reliant, and gendered care arrangements to universal, publicly guaranteed care systems anchored in human rights. The central policy question is no longer whether care matters, but whether states are prepared to assume responsibility for it. Recognising care as a human right necessitates a reallocation of power, resources, and institutional priorities – moving care from the margins of welfare policy and private households to the core of public systems and legal frameworks. Without this shift, care will remain unequal, underfunded, and gendered. With it, care can become a universal guarantee, advancing dignity, equality, and social justice across the life course.

Trade Union Advocacy

Trade unions are critical to advancing this agenda but must move beyond a narrow sectoral framing. Care should be understood as a structural labour issue affecting all workers—not only those employed in care occupations. Priority actions include:

• Integrating care demands into collective bargaining agendas across sectors

• Leading campaigns for public investment and universal care systems

• Organising and representing precarious, informal and migrant care workers

• Building strategic alliances with feminist, disability, and migrant rights movements

• Advancing internal transformation to centre gender equality and care within union agendas

Priority Actions

To operationalise care as a human right, the following actions are essential:

• Codify the right to care in law: Enact national legislation explicitly recognising the right to care, to be cared for, and to self-care; and embed these rights within constitutional or human rights frameworks with clear justiciability and enforcement mechanisms; and align domestic legal frameworks with emerging international standards, including the IACHR advisory opinion.

• Establish universal, publicly financed care systems: Transition from targeted, means-tested programmes to universal entitlements based on need across the life course; guarantee access to childcare, long-term care, disability support, and health-related care as core public services; and ensure sustainable public financing through progressive taxation, while reducing dependence on market-based provision. This also requires addressing the constraints imposed by austerity measures and debt burdens, which have historically undermined investment in care systems and weakened their capacity.

• Rebuild and expand public provision of care services: Prioritise direct public and non-profit provision, including re-municipalisation where privatisation has undermined access or quality; limit profit extraction and financialisation in essential care services through regulation and public ownership models; and invest in infrastructure, workforce capacity, and integrated service delivery systems.

• Transform labour conditions for paid care workers: Guarantee decent work for all care workers - including those in informal, domestic, and migrant care roles - through fair wages, secure contracts, social protection, occupational health and safety, and full labour rights, including collective bargaining and the right to unionise; and implement workforce strategies addressing recruitment, retention, training, and professionalisation.

• Recognise, reduce, and redistribute unpaid care work: Expand public services and social infrastructure to reduce unpaid care burdens; introduce comprehensive paid parental, paternity, and carers’ leave to promote equitable redistribution; and integrate unpaid care into national statistics and economic planning, including time-use data.

• Build integrated governance and accountability mechanisms: Establish cross-sectoral coordination bodies with clear mandates for care policy design and implementation; develop monitoring systems covering access, affordability, quality, and workforce conditions; and ensure meaningful participation through structured social dialogue of trade unions representing care workers within the care system, alongside the broader engagement and participation of labour movements, feminist organisations, disability groups, and care recipients in decision-making.

• Centre equity and inclusion in care systems: Design care systems that explicitly address the needs of women, persons with disabilities, older persons, migrants, and informal workers; eliminate exclusion based on employment status, income, migration status, sexual orientation, characteristics or gender identities; and recognise care recipients as rights-holders with autonomy and agency.

End Notes

This study was undertaken by Georgia Montague-Nelson from the Global Labour Institute, Manchester, UK (https://www.gli-manchester.net).  

Thanks to all those who agreed to be interviewed, provided feedback, shared resources and information that were used in this guide including: 

• Émilie Beauchesne, FIQ Quebec  

• Everline Aketch, PSI 

• Faith Lumonya, PSI 

• Kate Lappin, PSI 

• Lina Abou-Habib, Asfari Institute for Civil Society & Citizenship 

• Najwa Hanna, PSI 

• Samantha Howe, EPSU 

• Sandra Massiah, PSI 

• Sharleen Stewart, SEIU Canada 

• Tara Paterson, CUPE 

• Tichaona Fambisa, PSI 

• Verónica Montúfar, PSI 

• Ziona Tanzer, Solidarity Centre 

Thanks also to the members of the Rebuilding the Social Organisation of Care (RSOC) core group including in particular Wangari Kinoti (Action Aid), Valentina Contreras, GI-ESCR, Mahinour ElBadrawi (CESR), Amina Hersi (Oxfam), Alejandra Lozana (GI-ESCR), Nicole Maloba (FEMNET) and Grace Namugambe (FEMNET).