Employers who operate a holiday year from 1 April to 31 March will face an unusual situation between 2026 and 2028. Under the Working Time Regulations 1998 (WTR), full-time employees are entitled to 5.6 weeks' annual leave (equating to 28 days, inclusive of bank holidays – 20 days' annual leave plus the usual eight bank holidays). Due to the changing dates of Easter, the period from April 2026 to March 2027 will include 10 bank holidays, while April 2027 to March 2028 will include only six.

What does this mean if you operate a holiday year running from April to March?

The starting point is to check the precise wording of your contracts of employment. If the wording states:

• "You are entitled to 20/25 days' leave plus all bank holidays," then:

  (a) For 2026–2027, employees would be entitled to two additional bank holidays, increasing their total entitlement to 30 days.

  (b) For 2027–2028, employees would only receive six bank holidays under the contract wording, giving a total entitlement of 26 days. As this falls below the statutory minimum of 28 days, employers will need to award an additional two days' paid annual leave to remain compliant with the WTR.

• "You are entitled to 20/25 days' leave plus eight bank holidays," then:

  (a) For April 2026 to March 2027, employers may decide not to award the two additional bank holidays because the contract specifies the exact number of bank holidays to which employees are entitled. There is no automatic right to time off in lieu. If employers choose to grant the additional bank holidays, they cannot deduct these from the employee's 20 days' statutory annual leave without specific agreement. Instead, employers may require employees to work on those additional bank holidays. However, this may not be possible where the business is closed and may prove unpopular even where it is operational. Employers could consider remote working as an alternative. To maintain good employee relations, some employers may choose to award the additional days.

  (b) For April 2027 to March 2028, as there will only be six bank holidays, employers will need to award an additional two days' annual leave to comply with the statutory minimum under the WTR.

• "You are entitled to 28 days' leave inclusive of bank holidays," then there is no issue with breaching the statutory minimum entitlement, as employees will continue to receive 28 days' leave regardless of the number of bank holidays.

  (a) For April 2026 to March 2027, employees will take their usual 28 days' holiday, of which 10 days will be bank holidays.

  (b) For April 2027 to March 2028, employees will take 22 days' annual leave together with six bank holidays, totalling 28 days.

• "You are entitled to 25 days' leave plus bank holidays," then:

  (a) For April 2026 to March 2027, employees would be entitled to 35 days' total leave (25 days' annual leave plus 10 bank holidays).

  (b) For April 2027 to March 2028, employees would be entitled to 31 days' total leave (25 days' annual leave plus six bank holidays).

Employers operating an April to March holiday year will find themselves in an unfamiliar position, and this could lead to errors that result in breaches of the minimum holiday entitlement under the Working Time Regulations. The HR Helpline is available on 01455 852 028 to provide advice and assistance to help employers remain compliant with the statutory requirements.