In England and Wales, there are typically eight bank holidays each year: New Year’s Day, Good Friday, Easter Monday, two May bank holidays, the August bank holiday, Christmas Day, and Boxing Day. Occasionally, an extra bank holiday is granted for special events, such as Queen Elizabeth II’s Platinum Jubilee or the coronation of King Charles III. However, in most years, the standard number remains eight.
Most bank holidays occur on fixed dates, but Easter is an exception, as its timing shifts each year. Last year, Easter fell in March, whereas in 2025, it will be in mid-April. As a result, between 1st April 2024 and 31st March 2025, only seven bank holidays will take place.
Impact on Employers and Holiday Entitlements
Employers operating on a holiday year from 1st April to 31st March should be aware of the potential impact. Employees on the statutory minimum holiday entitlement could be affected, as UK law requires full-time employees to receive at least 28 days of annual leave, which includes bank holidays. Since there will only be seven bank holidays in the 2024-2025 period, some workers may only receive 27 days off, which would fall below the legal requirement.
Key Considerations for Employers
The implications will depend on how holiday entitlement is stated in employment contracts. If a contract specifies 28 days of annual leave, inclusive of bank holidays, there is no issue. Employees will still receive 28 days off—seven bank holidays and 21 days of their choosing. If a contract states entitlement as ‘20 days plus bank holidays’, a problem arises, as only seven bank holidays will fall within the 2024-2025 holiday year. This would leave employees with just 27 days off—below the statutory minimum. Employers in this situation should consider allowing affected employees an additional day of leave to remain compliant.
Risks and Next Steps
Employers who fail to address this issue could face claims for unlawful deductions from wages due to holiday underpayment. The fact that there were nine bank holidays in 2023-2024 does not offset this shortfall—employment tribunals will assess each holiday year independently.
To manage this risk, businesses should:
- Review employee holiday years to identify those following the 1st April – 31st March period.
- Determine how many employees are on statutory minimum holiday entitlement.
- Examine the wording of contracts to see if entitlement is defined as ‘plus bank holidays,’ which may create a compliance issue.
- Decide on a course of action—either granting an additional leave day to affected employees or taking the risk of potential legal challenges.
The good news is that this is a temporary issue; Easter will fall in April again in 2026, meaning the standard bank holiday pattern will resume for the 2025/26 holiday year.
If staying on top of holiday entitlement seems a daunting task, why not outsource your payroll to us here at Payroll Junction? We’ll make sure you’re always on the right side of the law. Get a quote today!