Easter has passed – but a complex holiday risk remains for employers

With Easter now behind us, many employers are returning to day-to-day operations. However, for employers operating an April–March holiday year, the current leave period presents a less obvious challenge that is easy to overlook.

The 2026/2027 leave year includes an unusual calendar alignment, with two Easter weekends falling within the same leave year. As a result, there are more bank holidays than in a typical year, a variation that can have significant implications for how annual leave entitlement is applied in practice.

Why 2026/2027 is different

The unusual alignment of Easter has created a “fat” year. Without proactive absence management, such fluctuations can lead to issues.

For employers with a leave year running from 1 April 2026 to 31 March 2027, the calendar results in up to 10 bank holidays, rather than the usual eight.

This is followed by the 2027/2028 leave year, where fewer bank holidays fall within the same period.

While these fluctuations are a normal feature of how Easter dates move, they can create unintended consequences where contractual holiday entitlement is not aligned with the calendar year in practice.

Why this matters for compliance

Under the Working Time Regulations 1998 (WTR), full-time employees are entitled to a minimum of 5.6 weeks’ paid annual leave per year, which equates to 28 days for someone working a five-day week.

The challenge arises where contractual wording interacts with a higher or lower number of bank holidays in a given year. Without careful management, employers may:

• Provide more leave than intended.
• Fall below statutory minimum entitlement.
• Create inconsistencies across the workforce.

This can lead to:

• Breach of contract claims.
• Unlawful deduction from wages claims.
• Employee relations issues.
• Increased administrative complexity when correcting entitlements.

What employers should be reviewing

For organisations currently operating within the 2026/2027 leave year, this period presents an important opportunity to review:

• Employment contracts
• Holiday policies
• HR systems and processes

The key consideration is straightforward: how is annual leave defined contractually, and how does that interact with this year’s bank holidays?

If contracts state “20 days plus bank holidays”

If your contracts provide “20 days’ annual leave plus bank holidays”, this is where the biggest risk lies.

In the current leave year, employees may be entitled to:

• 20 days’ annual leave
• 10 bank holidays

This creates a total entitlement of 30 days, exceeding what many employers may have anticipated.

If these additional bank holidays are not honoured, employers risk breaching contractual terms and triggering employee grievances or claims.

What are the options?

• Seek agreement to adjust entitlement across this and the following leave year.
• Allow the additional leave, which is often the most straightforward approach.
• Plan ahead for the next leave year to ensure statutory minimums are maintained.

If contracts state “28 days including bank holidays”

This structure avoids many of the challenges associated with fluctuating bank holidays.

Employees remain entitled to 28 days in total, regardless of how many bank holidays fall within the leave year.

As a result, employers benefit from:

• Greater consistency
• Simplified administration
• Reduced risk of contractual disputes

If contracts state “20 days plus 8 bank holidays”

This wording creates a more controlled position, as entitlement to bank holidays is capped.

However, employers should proceed with care. It is important to assess:

• Whether contract wording is clear and consistently applied.
• Whether any custom and practice has developed over time.

Where employees have historically been given all bank holidays as leave, expectations may override the written terms, increasing legal risk.

Practical steps for employers

To manage this effectively, employers should review holiday entitlement by:

• Auditing contract wording across the organisation.
• Communicating clearly with employees about how entitlement is applied.
• Seeking agreement where changes are required.
• Recording decisions to ensure consistency.
• Planning ahead for future leave years.

A proactive approach will reduce the risk of disputes and avoid the need for reactive adjustments later.

Managing holiday entitlement with confidence

Looking ahead, calendar variations like this are predictable. By reviewing contracts, planning proactively, and communicating clearly, employers can mitigate risk.

Variations in the holiday calendar are an inevitable feature of the UK leave system, but the risks they introduce are manageable with the right approach.

Employers who take the time to review their contractual frameworks, align policies with the calendar, and communicate clearly with their workforce will be better placed to:

• Maintain compliance with the Working Time Regulations.
• Ensure fairness and consistency in leave entitlement.
• Reduce administrative complexity.
• Support trust and engagement across their organisation.

Addressing these issues during the current leave year not only mitigates immediate risk but also establishes a more resilient and predictable approach to annual leave management in the years ahead.

How SafeHR can help

Managing annual leave entitlement, particularly in unusual calendar years like 2026/2027, can quickly become complex. Getting it wrong can expose employers to legal risk, employee dissatisfaction, and administrative challenges.

SafeHR supports employers in navigating these issues with confidence. Our team can:

• Review and audit your employment contracts and holiday policies.
• Identify potential compliance risks linked to bank holiday fluctuations.
• Provide clear, practical guidance on managing entitlement fairly and consistently.
• Support with employee communications and implementing changes.
• Help future-proof your approach to annual leave management.

Whether you need a one-off review or ongoing HR support for small business, SafeHR is here to help you stay compliant, reduce risk, and manage your workforce effectively.