Holidays Act 2003

If you are running a business today, the Holidays Act 2003 is still the leave law you need to follow. The Employment Leave Act 2026 has been enacted, but its main framework does not generally start until 6 August 2028 and, in most cases, the current law continues until the first pay period starting on or after that date under the transition rules.

That means annual holidays, sick leave, public holidays and alternative holidays should still be managed under the Holidays Act until the legal transition point arrives.

The practical approach is straightforward. Keep current Holidays Act compliance stable, and use the lead-in period to improve agreement wording, roster clarity, record quality and payroll data. The future Act will use an hours-based structure, so those basics will matter.

This is planning, not a reason to change live payroll calculations early.

The move from the Holidays Act to the Employment Leave Act is not a wipe-and-restart exercise. Schedule 1 says existing annual holidays, sick leave and alternative holidays are converted under transition rules. In most cases, the current Act also continues until the first pay period starting on or after commencement.

That is why employers should avoid promising a simple rollover method too early.

If your business has concerns about past Holidays Act underpayments, keep that issue on its own track. The Employment Leave Act 2026 allows a regulated remediation process for eligible pre-existing employers, but that is separate from the future leave framework and is not the only way liabilities may be resolved.

In short, keep complying with the Holidays Act now and treat planning for the new framework and historic remediation as separate issues.