United States | Scheduled statutory benefits, no pain-and-suffering awardState workers-compensation schedules; value tracks the impairment rating, the wage rate and future medical, and most claims close by compromise-and-release rather than verdict. | State workers-compensation schedules; value tracks the impairment rating, the wage rate and future medical, and most claims close by compromise-and-release rather than verdict. |
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United Kingdom· you are here | Valued on the JC Guidelines bracket for the underlying injuryEmployer-liability claims carry no separate tariff, the injury bracket governs, applied as in any negligence claim. | Employer-liability claims carry no separate tariff, the injury bracket governs, applied as in any negligence claim. |
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Ireland | Valued on the Personal Injuries Guidelines bracketAssessed by the Injuries Resolution Board under the Personal Injuries Guidelines (2021), which replaced the Book of Quantum. | Assessed by the Injuries Resolution Board under the Personal Injuries Guidelines (2021), which replaced the Book of Quantum. |
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Canada | Statutory no-fault benefits, no general-damages awardProvincial workers-compensation boards pay wage-loss and permanent-impairment benefits; in exchange workers are barred from suing the employer. | Provincial workers-compensation boards pay wage-loss and permanent-impairment benefits; in exchange workers are barred from suing the employer. |
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Australia | Statutory lump sum by whole-person impairmentEach state scheme sets its own WPI threshold for access to common-law damages; below the threshold only statutory benefits are payable. | Each state scheme sets its own WPI threshold for access to common-law damages; below the threshold only statutory benefits are payable. |
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Spain | Social Security incapacity benefit, plus baremo award on any civil claimOccupational contingencies are covered by Social Security; the baremo scale governs any civil claim beyond it. | Occupational contingencies are covered by Social Security; the baremo scale governs any civil claim beyond it. |
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Italy | INAIL indemnity by impairment percentageCompulsory INAIL cover indemnifies occupational injury; a civil action against the employer requires fault beyond the insured risk. | Compulsory INAIL cover indemnifies occupational injury; a civil action against the employer requires fault beyond the insured risk. |
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Germany | Statutory accident-insurance benefits, no Schmerzensgeld from the employerDGUV cover replaces employer liability; Schmerzensgeld lies only where the employer acted intentionally (SGB VII paras 104-105). | DGUV cover replaces employer liability; Schmerzensgeld lies only where the employer acted intentionally (SGB VII paras 104-105). |
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France | CPAM benefits; enhanced award only on faute inexcusableOccupational accidents are compensated through the CPAM scheme; full tort damages require proof of the employer faute inexcusable. | Occupational accidents are compensated through the CPAM scheme; full tort damages require proof of the employer faute inexcusable. |
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New Zealand | ACC weekly compensation and lump sum, no right to sueThe Accident Compensation scheme bars personal-injury litigation entirely; entitlements are statutory. | The Accident Compensation scheme bars personal-injury litigation entirely; entitlements are statutory. |
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Singapore | Statutory ceilings for death and permanent incapacityWork Injury Compensation Act as amended 2020, a no-fault route with statutory limits, or a common-law claim instead, but not both. | Work Injury Compensation Act as amended 2020, a no-fault route with statutory limits, or a common-law claim instead, but not both. |
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Hong Kong | ECO statutory compensation by age and incapacityEmployees Compensation Ordinance (Cap. 282), no-fault statutory compensation; a common-law negligence claim may run in addition. | Employees Compensation Ordinance (Cap. 282), no-fault statutory compensation; a common-law negligence claim may run in addition. |
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Japan | Workers-accident-compensation benefit by disability gradeRosai labour-standards insurance pays by disability grade; a separate civil claim requires proof of a safety-duty breach. | Rosai labour-standards insurance pays by disability grade; a separate civil claim requires proof of a safety-duty breach. |
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South Korea | IACI benefit by disability gradeIndustrial Accident Compensation Insurance Act, statutory benefit by grade; civil damages require employer fault. | Industrial Accident Compensation Insurance Act, statutory benefit by grade; civil damages require employer fault. |
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Taiwan | Labour-insurance disability benefit by gradeOccupational Accident Labour Protection framework; employer civil liability runs in parallel with the insurance benefit. | Occupational Accident Labour Protection framework; employer civil liability runs in parallel with the insurance benefit. |
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