Issues Arising from the 2026/27 Leave Year: Additional Public/Bank Holidays

We all love a Public/Bank holiday, don’t we? Unless you are in the Payroll Department of course, when the holiday year is April to March, and Easter jumps around between April and March.  For the holiday year of April to March of 2026/27, the reality is that there are 2 sets of Easter Public/Bank holidays within the same holiday entitlement.  How do you deal with this?

The Law on Public/Bank Holidays

All employees are entitled to a set number of days off work each year by way of paid leave. The minimum statutory annual leave entitlement is 5.6 weeks’ paid holiday per year, which for a full-time employee equates to 28 days.

While this entitlement is often described as 20 days’ annual leave plus 8 Public/Bank Holidays, the law does not require employers to provide Public/Bank holidays in addition to statutory leave. Employers can choose to include Public/Bank holidays within the statutory entitlement.

In practice, this means:

• Employers may require employees to take Public/Bank holidays as part of their annual leave entitlement if the workplace is closed.

• Employers may provide Public/Bank holidays in addition to annual leave.

• Employees may be required to work on Public/Bank holidays, depending on business needs.

Ultimately, whether Public/Bank holidays are included within annual leave or provided in addition to, it will depend on the wording of the employment contract and associated policies.

The effect of Easter when the holiday year runs April to March

In most years, there are eight Public/Bank holidays in England and Wales. However, the number of Public/Bank holidays falling within a leave year can vary depending on when Easter occurs.

For employers whose holiday year runs from 1^st April to 31^st March, the 2026/27 leave year is unusual because 10 Public/Bank holidays fall within that period.

This occurs because both:

• Good Friday – 3^rd April 2026

• Easter Monday – 6^th April 2026

fall shortly after the start of the leave year, and the following Easter also falls within the same leave year:

• Good Friday – 26^th March 2027

• Easter Monday – 29^th March 2027

As a result, employers operating an April to March leave year will see 10 Public/Bank holidays during the 2026/27 holiday year, rather than the usual eight.

Does this mean employees get extra leave?

Whether employees receive additional leave depends entirely on how holiday entitlement is expressed in the employment contract.

Employers should review contracts and policies now to determine how these additional Public/Bank holidays will affect leave entitlement.

Common contractual wording and what it means

Below are examples of commonly used holiday clauses, and how they may operate in the 2026/27 leave year.

1. “20 days’ holiday per annum plus Public/Bank holidays”

Yes – employees will be entitled to the additional Public/Bank holidays.

Because the contract refers to all Public/Bank holidays, employees will receive any Public/Bank holiday that falls within the leave year.

In 2026/27, this means employees would receive:

·       20 days annual leave, plus

·       10 Public/Bank holidays

Employers should, therefore, prepare for two additional days of paid leave for affected staff.

2. “28 days’ holiday per annum, including Public/Bank holidays”

No change to entitlement.

Employees still receive 28 days’ total leave.

Where the workplace closes over Easter, employees would take those days as part of the 28-day allowance.

In 2026/27, this means employees will take 10 paid days of leave over the 2 Easters, but this will be deducted from their full 28 days entitlement, leaving 18 days to book at other times.

3. “20 days’ holiday per annum plus 8 Public/Bank holidays”

No automatic entitlement to the 2 additional Public/Bank holidays.

This wording effectively caps the entitlement at eight Public/Bank holidays. Any additional Public/Bank holidays would only be provided at the employer’s discretion.

4. Contracts listing specific Public/Bank holidays

For example:

“In addition, you will receive pay on or in respect of the following eight Public/Bank holidays: New Year’s Day, Good Friday, Easter Monday, May Day, Spring Bank Holiday, Late Summer Bank Holiday, Christmas Day and Boxing Day.”

Where the contract specifies the exact holidays, and the amount has been capped to eight Public/Bank holidays, then employees are only entitled to the first eight Public/Bank holidays.  So, the second Easter would be discretionary. 

However, if the Public/Bank holidays are simply listed and no mention is made that there is a total of eight, then it could well be argued that employees would be entitled to the two additional days over Easter 2027. So, as always, it depends on the care taken in how contractual terms are written.

Requests for Time Off Work

Even though employees are entitled to a minimum amount of paid leave each year, employees are not normally entitled to dictate when that leave is taken.

Employers are responsible for ensuring appropriate staffing levels and maintaining operational continuity. As such, employers may:

• restrict the number of employees who can take leave at the same time;

• require employees to take leave on specific dates (for example, when the organisation closes such as over Easter);

• decline requests where operational needs require staffing;

Where additional Public/Bank holidays fall within a leave year, employers should ensure that any decisions regarding leave requests are handled fairly and consistently.

Clear communication will help manage expectations and avoid unnecessary employee relations issues.

Practical Steps for Employers

To avoid confusion or potential disputes during a 2026/27 April to March leave year, employers should consider the following actions:

• Review employment contracts and holiday policies to identify how Public/Bank holidays are treated.

• Check whether contractual wording creates entitlement to additional leave, or not.

• Assess the potential cost and operational impact if employees receive extra leave.

• Ensure part-time employees’ entitlements are correctly pro-rated.

• Communicate the organisation’s approach clearly to employees before the new leave year begins, so you do not have much time.

The guidance provided in this article is just that - guidance. Before taking any action, make sure that you know what you are doing, or call an expert for specific advice