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Comparative Summary

This report by the foreign law research staff of the Law Library of Congress’s Global Legal Research Directorate includes surveys of the regulation and funding of two types of alternative maternity care providers, midwives and doulas, in ten countries around the world. The jurisdictions covered are Brazil, Canada, Hong Kong, France, Germany, Israel, Japan, New Zealand, Sweden, and England.

All researched jurisdictions regulate the work of midwives, which is not the case when it comes to doula activities.  In Brazil legislation is pending in Congress that would also regulate the work of doulas, and states and municipalities have already enacted such laws.  Although New Zealand does not regulate the activity, doulas may be required to comply with a code of consumer rights to the extent they provide health services to the public.  All other jurisdictions do not regulate doula activities. 

To work as a midwife in the countries surveyed usually requires previous qualification or experience.  In general, a person needs to have specific education and training, and pass an exam.  The exceptions are Sweden and Japan.  In the case of Sweden only educated and trained nurses can become midwives and in Japan a woman must first acquire the qualification for the national nursing examination and then receive the education for midwifery to qualify for the national midwifery examination.

Professional educational requirements for doulas in countries that do not regulate the activity are basically nonexistent.  Professional classes and voluntary certification for doulas are offered by professional organizations in Germany, Japan, Sweden, and the UK.  State law in Brazil requires a person to obtain a certificate of professional training to work as a doula.

Midwifery work in all the surveyed jurisdictions involves, to some degree, maternity care during pregnancy, labor, and the postpartum period.  Brazil has also created a subsystem of assistance that allows the parturient to designate a person to accompany her during labor, delivery, and immediate postpartum.  In addition a network was created within the country’s health system to provide women with health, quality of life, and well-being during pregnancy, childbirth, and the postpartum period, and to provide child development support through the first two years of a child’s life.

In the countries that acknowledge their work, the job of doulas focuses on what is considered nonmedical assistance and services, either in the form of physical assistance, emotional support, or therapeutic relief, as is the case in Hong Kong, Israel, and New Zealand, or in the form of housekeeping, cooking, childcare, and mental support for the new mother and her family, as occurs in Japan.  In Brazil, state law allows the presence of doulas during labor, delivery, and immediate postpartum. Sweden offers doulas in lieu of other support to women who do not have a support person to accompany them during labor, and in some regions of the country offers “cultural doulas” to work as interpreters and facilitators for immigrant mothers with limited language skills. 

Health care, which includes midwife services, is funded either by the government at the federal, provincial, territorial, or local level, as is the case in Brazil, Canada, Hong Kong, New Zealand, Sweden, and the United Kingdom, or by a national health insurance scheme as occurs in France, Germany, Israel, and Japan.  Doula services are not funded in the vast majority of the researched jurisdictions, with the exception of Brazil, which provides funding at the state and municipal levels, and Sweden, where municipal health care services may fund doulas in lieu of other support and cultural doulas.  Also, in Canada some private insurance companies have started to cover doula services.

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Comparative Summary by:
Eduardo Soares
Senior Foreign Law Specialist
May 2019

Countries Surveyed for Report:

Global Legal Research Direcorate Staff
May 2019

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Last Updated: 12/30/2020