Great Britain
Rolled-up holiday pay sits in the Working Time Regulations 1998, which cover England, Wales and Scotland. Northern Ireland has its own working time regulations — if your venue is there, check the position locally rather than assuming this applies.
Rolled-up holiday pay is holiday pay added to every payslip as a 12.07% uplift on what the member of staff earned, instead of being paid when they take their holiday. It is lawful for irregular-hours and part-year staff only, for leave years beginning on or after 1 April 2024, and it has to appear on the payslip as its own figure.
Almost every explanation of it stops there. The part that is harder to find is what the payslip actually looks like, and what is still outstanding once it has been paid — because paying the money is not the same as discharging the holiday. This post takes one month of a fifteen-person pub and works one payslip line by line.
Quoted
Regulation 16A, in its own words
Holiday pay “may be paid by way of a 12.07% uplift to the worker’s remuneration for work done”, it “must be paid at the same time as the worker’s remuneration for work done”, and “any itemised pay statement provided by the employer to the worker must indicate the amount of holiday pay that has been paid for the period to which the statement relates.”
Who you can pay it to, and who you cannot
Regulation 16A opens by naming exactly what it reaches: holiday pay due “in respect of leave to which the worker is entitled under regulation 15B”. Regulation 15B is the accrual regulation for irregular-hours and part-year workers. Everybody else’s holiday pay is untouched by it.
So the eligibility test is the contract test in regulation 15F — the same test that decides whether someone accrues at 12.07% in the first place:
- An irregular hours worker is one whose paid hours in each pay period are, under the terms of their contract, wholly or mostly variable.
- A part-year worker is required to work only part of the year, with periods of at least a week inside it that they are not required to work and are not paid for.
In the pub this post follows, eleven of the fifteen are on those contracts — bar staff, waiting staff, a kitchen porter, a casual chef de partie, a glass collector. The general manager, head chef, sous chef and one full-time bartender are on fixed contracted hours. Rolled-up holiday pay is available for the eleven and not for the four, and no amount of payroll convenience changes that.
One method for everybody is the expensive version
Rolling up holiday pay for a fixed-hours member of staff does not just pay them early. It pays them something regulation 16A does not recognise as holiday pay at all, and leaves the underlying obligation in regulation 16 exactly where it was. There is more on what that costs further down.
The payslip, line by line
One monthly pay period, ending 31 August 2026. This is the pub’s busiest bartender — 122 hours and 30 minutes worked, some of it as duty supervisor at a higher rate. Wages are at the National Living Wage of £12.71 an hour for staff aged 21 and over, in force from 1 April 2026.
The holiday line is one multiplication, and it is worth doing slowly once because it is the only sum on the page.
Three things on that payslip are there because a rule puts them there, and all three are easy to lose in a payroll set up for salaried staff.
The holiday line is its own figure. Regulation 16A(7) requires the itemised pay statement to indicate the amount of holiday pay paid for the period the statement relates to, and Acas says to show it as a separate payment. One gross number does not meet that, and neither does an hourly rate quietly inflated from £12.71 to £14.24 with a note somewhere saying holiday is included.
The hours are on it too, and that is a different rule. Since 6 April 2019, section 8(2)(e) of the Employment Rights Act 1996 has required an itemised pay statement to carry the total hours worked wherever pay varies by reference to time worked — either as one aggregate figure or as separate figures for different rates of pay. For variable-hours staff that is every payslip, and the payslip above uses the second option because the rates differ.
It is paid now, not later. Regulation 16A(3) requires rolled-up holiday pay to be paid at the same time as the remuneration for work done. A quarterly catch-up, or a lump sum at the end of the season, is not this method.
Why the hours line matters more than it looks
The hours figure on the payslip is the same number the accrual runs off. 122.5 hours worked is £191.21 of rolled-up holiday pay and — under regulation 15B — 15 hours of leave accrued in the same month. One figure, two obligations. If the hours on the payslip and the hours in the holiday record disagree, one of the two is wrong, and the payslip is the one the member of staff kept.
The 12.07% is of pay, not necessarily of basic pay
Regulation 16A(9) does not leave “remuneration” to the payroll’s judgement. It defines it as all types of payment that would be included when working out a week’s pay for the purposes of regulation 16 — and regulation 16(3ZA), in force since 1 January 2024, is explicit about what that takes in:
- payments intrinsically linked to the performance of tasks the worker is obliged to carry out under their contract;
- payments for professional or personal status relating to length of service, seniority or professional qualifications;
- other payments, such as overtime payments, which have been regularly paid in the preceding 52 weeks.
For a pub that is not an academic point. A bartender who does a regular Friday close at a higher rate, a chef on a service-related payment, a supervisor uplift that has been paid every month for a year — each of those is a question about what the 12.07% is a percentage of. Get the base wrong and every payslip is wrong by the same proportion, quietly, for as long as the arrangement runs.
Tips are a separate question with its own answer, and it turns on how the tips reach the staff rather than on the holiday rules. We went through those mechanics in the tronc post.
What the money does not buy
This is the part that catches venues, and it is worth stating flatly. Paying rolled-up holiday pay does not remove the holiday.
Regulation 16A(8) is carefully worded: an employer who pays this way “is discharged from their liability to make payments to the worker in the manner described in regulation 16 in respect of that annual leave”. The discharge is of the payment. The leave itself still accrues under regulation 15B — 15 hours for the bartender above, in August alone — and the employer, in Acas’s words, still has a legal duty to “make sure workers can take the holiday they’re entitled to” and to encourage them to take it.
The consequence lands on the member of staff, and it is the one thing most worth saying out loud when you introduce this:
The week off is unpaid
Acas states it plainly: “Rolled-up holiday pay means a worker will not get any pay when they take holiday.” Somebody who has been getting £191 a month without registering what it was for will register the week in February with nothing in it. That conversation is much easier if the payslip has been saying “holiday pay” every month, which is exactly what regulation 16A(7) is for.
Acas also notes that employers should tell workers if they are planning to use rolled-up holiday pay, and that introducing it might involve changing employment contracts. It is a change to how people are paid, not a payroll setting.
When somebody goes off sick, the line keeps running
This is the corner most often missed, because it is the one place the 12.07% stops working — there are no hours to take a percentage of.
Regulation 16A(4) to (6) answer it with an average. A worker who was being paid rolled-up holiday pay before going on sick leave or statutory leave must keep receiving it, in each pay period of that leave, at the average amount they were paid per pay period over the relevant period: the 52 weeks ending with the day before the leave started, or a shorter period if rolled-up pay has been running for less than 52 complete weeks.
Two things follow from that sum. It needs twelve months of holiday-pay history per person, kept separately from wages, or it cannot be done at all. And it is a payment the payroll has to keep making while somebody is absent — the opposite of how most systems behave when a variable-hours member of staff stops appearing on the rota.
Rolling it up for the wrong person
Take regulation 16A(1) and 16A(8) together, because between them they say what happens when this is applied to a fixed-hours member of staff.
Regulation 16A reaches holiday pay due for regulation 15B leave. Somebody on fixed contracted hours does not accrue under regulation 15B — they get 5.6 weeks of their own working pattern, capped at 28 days, and their holiday pay is due under regulation 16 in the ordinary way. Regulation 16A(8) discharges that regulation 16 liability only where the payment was made under regulation 16A. For someone outside the regulation, no such payment exists.
What that means in practice
The 12.07% added to a full-time bartender’s payslip every month is not holiday pay under these regulations. It has been paid, and it is gone. The obligation to pay them a week’s pay for each week of leave they take is still sitting there, unpaid, for as long as the arrangement runs — and the payslips are the record of it.
The fix is not complicated, and it is the same fix as for the accrual method: sort the staff list by contract, once, and let the contract decide the method. The pub’s four fixed-hours staff are on 5.6 weeks and paid when they take it. The eleven are on 12.07% and can be rolled up. We worked the accrual side of that split, hour by hour, in the 12.07% post.
If your contracts give more than the statutory minimum
Regulation 16A names 12.07%, and 12.07% is the figure for the statutory minimum of 5.6 weeks — 5.6 against the 46.4 working weeks left in the year. Acas puts the requirement as at least 12.07% of total pay in the pay period, which is the same point from the other end: the percentage has to match the leave you have actually promised.
GOV.UK works the sum for a contract giving six weeks: 6 ÷ 46 = 0.1304, so 13.04%. If your contracts are more generous than the minimum and you are rolling up on a percentage, the percentage is not 12.07.
What is coming
Rolled-up holiday pay itself is settled — it went into the regulations for leave years beginning on or after 1 April 2024, and nothing announced changes it. What is moving is who checks.
The consultation closes 22 September 2026
GOV.UK published Make Work Pay: holiday pay compliance and enforcement on 30 June 2026, and it closes at 11:59pm on 22 September 2026. It sets out how the Fair Work Agency is to enforce workers’ rights to statutory holiday pay, alongside the existing employment tribunal route rather than in place of it, with enforcement intended to begin in 2027.
That sits on top of a duty already live: since 6 April 2026 you have had to keep records adequate to show that holiday entitlement and holiday pay were right, and keep them for six years. For a venue running rolled-up pay the records question has a specific shape — the hours, the pay for work done, the 12.07% taken from it, and the payslip that showed it. We went through that duty in full in the six-year holiday records post.
What this means for how you keep the rota
Rolled-up holiday pay looks like the simple option, and for the right staff it is. What it actually needs is three numbers per person per pay period, all of them durable: hours worked, pay for work done, and the holiday pay taken from it. Miss any one and the sick-leave average cannot be run, the records duty cannot be met, and neither can a member of staff’s question about what the extra line on their payslip was.
Three questions worth asking of however you do it today:
- Does your payslip name it? Not “included in your rate”, not a higher headline rate — a figure, labelled holiday pay, for the period the payslip covers.
- Can you produce a year of holiday-pay figures for one person? That is the whole of the sick-leave calculation, and it is not reconstructible from a bank statement.
- Does your staff list say who is on which method? The contract decides it, not the rota. Eleven and four, in this pub, and the four are the expensive ones to get wrong.
None of that needs software. It needs the hours to exist somewhere durable, tied to real people and real pay periods, with the pay line beside them. If the rota already produces the hours as a by-product of running the venue, the rest is a multiplication.