Many UK businesses align their annual leave with the calendar year (January to December), which tends to avoid complications when it comes to bank holidays. However, if your holiday year runs from 1 April to 31 March, it’s worth checking your entitlement this year to make sure you’re staying compliant.
What’s the issue?
In 2024, Good Friday fell on 29 March – right before the new holiday year began. This means that for businesses with a 1 April to 31 March leave year:
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9 bank holidays landed in the 2023–24 holiday year
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Only 7 bank holidays fall into the 2024–25 holiday year
That’s a shortfall – and it could mean some employees are receiving less than their statutory minimum of 28 days (pro rata for part-time staff) this year.
Why it matters
The Working Time Regulations 1998 require all employees to receive at least 28 days of paid annual leave per year. If an employee had 29 days last year due to the extra bank holiday, but only receives 27 days this year, you could be in breach of employment law.
Remember: the statutory minimum must be met each year – extra days in one year can’t be used to make up for a shortfall in the next.
What should you do?
✅ Top up your employees’ leave for 2024–25 to make sure they still receive the full 28 days (pro rata for part-time staff). This might mean manually adding one day to their allowance.
⚠️ While it may feel like the ‘extra day’ from last year balances things out, legally speaking, it doesn’t.
How to avoid this in future
It all comes down to what your employment contracts say:
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If your contract states “28 days including bank holidays” – you’re covered.
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If it refers to a set number of bank/public holidays (e.g. “8 bank holidays”) – check whether the actual number in your leave year matches up.
Regularly reviewing your contracts and holiday policy wording can help you avoid future compliance issues.
What about next year?
Good news – for the 2025–26 holiday year, the usual 8 bank holidays fall within the leave year, so this anomaly won’t be repeated.
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