For businesses operating across multiple regions, managing public holidays can be complex. Different countries, states, and territories have different public holiday calendars, and employees working on public holidays may be entitled to additional pay or substitute days off. This template provides a clear, multi-region public holiday policy that addresses substitute holidays, working on public holidays, and the interaction between public holidays and annual leave.

Key Takeaways

  • Public holiday entitlements vary by region — check local legislation for each jurisdiction where you have employees.
  • Substitute holidays (sub days) provide flexibility when public holidays fall on non-working days.
  • Working on public holidays may attract penalty rates or additional pay under employment contracts or modern awards.
  • Public holidays are separate from annual leave and should not be deducted from annual leave balances.

What This Template Covers

This template provides a complete public holiday and substitution policy for multi-region businesses. It covers the treatment of public holidays, substitute holidays, working on public holidays, penalty rates and additional pay, the interaction between public holidays and annual leave, and regional variations across the UK, Australia, and the US. It is designed for businesses with employees in multiple jurisdictions.


Public Holiday and Substitution Policy Template

1. Purpose

[Company Name] recognises that public holidays are an important part of employee rest and cultural observance. This policy outlines the arrangements for public holidays across all regions where [Company Name] operates, ensuring consistent treatment of employees while complying with local legislation.

2. Scope

This policy applies to all employees of [Company Name], regardless of their work location. It covers public holidays observed in the employee’s country, state, or territory of residence or employment.

3. Public Holiday Entitlement

[Company Name] provides employees with paid time off on public holidays that fall on their ordinary working days. Key provisions:

  • UK: Public holidays (bank holidays) are as specified in the Working Time Regulations 1998 and the Employment Rights Act 1996. There are currently 8 bank holidays per year in England, Scotland, Wales, and Northern Ireland.
  • Australia: Public holidays are as specified by the Fair Work Act 2009 and applicable state/territory legislation. There are typically 8–10 public holidays per year, varying by state/territory.
  • US: Public holidays are determined by federal, state, and local law. There are 10 federal public holidays per year, but state and local holidays may vary.

4. Substitute Holidays (Sub Days)

Where a public holiday falls on a day that is not an employee’s ordinary working day (e.g., a weekend), [Company Name] provides a substitute holiday (sub day) to ensure the employee receives their full entitlement. The sub day is:

  • Taken on the next working day following the public holiday, unless otherwise agreed between the employee and their manager.
  • Paid at the employee’s normal rate of pay.
  • Recorded as a public holiday, not as annual leave.

[Regional variations:]

  • UK: There is no statutory requirement for a substitute day when a bank holiday falls on a weekend. However, [Company Name] provides a sub day as a company benefit. [Note: Some contracts include the bank holidays as part of the statutory 5.6 weeks, in which case a sub day may not be applicable.]
  • Australia: Under the NES and applicable modern awards, substitute days are provided where a public holiday falls on a non-working day, unless the award specifies otherwise.
  • US: There is no federal requirement for substitute days. [Company Name] provides a sub day as a company benefit.

5. Working on Public Holidays

Where an employee is required to work on a public holiday (due to business needs, shift patterns, or operational requirements):

  • The employee will be paid at their normal rate of pay plus [penalty rate / additional X% loading] for hours worked on the public holiday.
  • [UK: Employees working on a bank holiday may be entitled to a substitute day off and/or additional pay under their employment contract or applicable collective agreement.]
  • [Australia: Employees working on a public holiday are entitled to penalty rates as specified by their applicable modern award (typically 150%–250% of their base rate).]
  • [US: There is no federal requirement for additional pay on public holidays, but [Company Name] provides a [X%] premium as a company benefit.]

6. Interaction with Annual Leave

  • Public holidays falling on a day the employee would normally work are not counted as annual leave days.
  • If a public holiday falls during a period of annual leave, the employee’s annual leave balance is not deducted for that day.
  • Employees do not need to take annual leave to observe a public holiday — it is a separate entitlement.

7. Regional Public Holiday Calendars

[Company Name] maintains a public holiday calendar for each region where employees are located. The calendars are updated annually and shared with employees via [HR platform / company intranet / email]. Employees should check the relevant calendar for their region to plan leave and work schedules.

[2026 Public Holiday Calendar — UK (England & Wales)]

Holiday Date
New Year’s Day 1 January
Good Friday 3 April
Easter Monday 6 April
Early May Bank Holiday 4 May
Spring Bank Holiday 25 May
Summer Bank Holiday 31 August
Christmas Day 25 December
Boxing Day 28 December

[2026 Public Holiday Calendar — Australia (NSW)]

Holiday Date
New Year’s Day 1 January
Australia Day 26 January
Good Friday 3 April
Saturday before Easter Sunday 4 April
Easter Sunday 5 April
Easter Monday 6 April
Anzac Day 25 April
Queen’s Birthday 8 June
Bank Holiday 3 August
Labour Day 5 October
Christmas Day 25 December
Boxing Day 26 December

[2026 Federal Public Holidays — US]

Holiday Date
New Year’s Day 1 January
Martin Luther King Jr. Day 19 January
Presidents’ Day 16 February
Memorial Day 25 May
Juneteenth 19 June
Independence Day 4 July
Labour Day 7 September
Columbus Day 12 October
Veterans Day 11 November
Thanksgiving Day 26 November
Christmas Day 25 December

Note: State and local holidays vary. Check the applicable calendar for each employee’s location.

8. Religious Observance

[Company Name] respects employees’ religious observance needs. Where an employee’s religious holidays do not align with the public holidays observed by [Company Name], the employee may request time off for religious observance through the annual leave process. [Company Name] will consider such requests sympathetically and make reasonable adjustments where possible.

9. Notification

  • The public holiday calendar for each region will be published by [December 1 / January 1] each year.
  • Employees required to work on a public holiday will be notified at least [2 weeks] in advance.
  • Sub day dates will be confirmed by the employee’s manager in consultation with the employee.

10. Policy Review

This policy will be reviewed annually or following changes to public holiday legislation in any region where [Company Name] operates.


Region Legislation Public Holidays Substitute Day Required?
UK Working Time Regulations 1996 8 bank holidays No statutory requirement
Australia Fair Work Act 2009 8–10 (varies by state) Yes (where specified in award)
US Federal/state law 10 federal + state/local No federal requirement

Customisation Tips

  • Centralise your calendar. Maintain a single, up-to-date public holiday calendar for all regions and share it widely.
  • Address remote workers. If employees work remotely from a different country than the company’s registered office, which public holiday calendar applies? Define this clearly.
  • Include cultural holidays. Consider offering a floating holiday for cultural or religious observance that does not align with the standard calendar.
  • Address time zones. For global teams, clarify whether public holidays are based on the employee’s local time zone or the company’s head office time zone.

Common Mistakes to Accrue or Lose Leave?

Can we require employees to work on a public holiday?

It depends on the jurisdiction and the employee’s contract. In the UK, there is no statutory right to time off on bank holidays unless the employment contract provides for it. In Australia, employees may be required to work on public holidays if their modern award allows it and reasonable notice is given. In the US, there is no federal requirement for time off on public holidays. Check the employee’s contract, applicable award, and local legislation.

Does a public holiday falling on a weekend mean the employee loses the day?

Not necessarily. Many companies provide a substitute day (sub day) when a public holiday falls on a weekend. The UK does not require this by law, but it is a common company benefit. Australia and some US states provide substitute days in certain circumstances. Check your company’s policy and applicable legislation.

Can we deduct a public holiday from annual leave?

No. Public holidays are separate from annual leave. If a public holiday falls during a period of annual leave, the employee’s annual leave balance should not be deducted for that day.


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