Paid leave entitlement varies more than almost any other employment right around the world — from generous statutory minimums across Europe to essentially zero legal requirement in the United States. Whether you're an employee negotiating a contract, an HR manager calculating pro-rata entitlement, or a business hiring internationally, understanding what the law requires in each country is essential. This guide covers the UK, US, EU, and other major jurisdictions — with formulas for every worker type.
The Universal Pro-Rata Formula
Pro-rata entitlement = Full-year allowance × (Months worked ÷ 12)
Part-time entitlement = Full-time days × (Days worked per week ÷ 5)
Irregular hours accrual = Hours worked in period × accrual rate %
These formulas apply in any country — only the "full-year allowance" figure changes based on local law or employer policy.
UK: 28-Day Statutory Minimum
All UK workers are legally entitled to a minimum of 5.6 weeks' paid holiday per year under the Working Time Regulations 1998. For full-time employees working 5 days a week, this equals 28 days — which may include the 8 UK bank holidays depending on your contract wording.
| Working pattern | Statutory entitlement | Calculation |
|---|---|---|
| Full-time (5 days/week) | 28 days | 5.6 × 5 |
| 4-day week | 22.4 days | 5.6 × 4 |
| 3-day week | 16.8 days | 5.6 × 3 |
| 2-day week | 11.2 days | 5.6 × 2 |
UK Irregular Hours Workers — 2024 Reform
From 1 April 2024, zero-hours and casual workers accrue holiday at 12.07% of hours worked per pay period, replacing the old 12-week reference period method.
Holiday hours accrued = Hours worked in period × 12.07%
Example: 120 hours worked this month → 120 × 0.1207 = 14.5 hours holiday accrued
Derivation: 5.6 weeks ÷ (52 − 5.6) weeks = 12.07%
What UK Holiday Pay Must Include
Following Supreme Court rulings (Bear Scotland v Fulton, 2014), UK holiday pay must reflect "normal pay" — not just basic salary. It must include regular overtime, regular commission, shift premiums paid regularly, and on-call payments if they form a normal part of pay. Basic-pay-only calculations are legally incorrect and claims can go back 2 years.
United States: No Federal Minimum
The US is unique among wealthy nations — there is no federal law requiring employers to provide paid vacation leave. The Fair Labor Standards Act governs minimum wage and overtime but says nothing about paid time off. What US workers receive depends entirely on employer policy and, in a small number of states, state law.
| Country | Statutory paid leave | Public holidays | Typical total |
|---|---|---|---|
| United Kingdom | 20 days (can include bank holidays) | 8 days | 28 days minimum |
| United States | 0 days (no federal requirement) | 0 days statutory | 0 days legally required |
| Germany | 20 days | 9–13 days (by state) | 29–33 days |
| France | 25 days | 11 days | 36 days |
| Australia | 20 days | 10–12 days | 30–32 days |
| Canada | 10–15 days | 9–13 days | 19–28 days |
| Japan | 10–20 days (by service length) | 16 days | 26–36 days |
In practice, most US private-sector employers offer 10–15 days of paid vacation as a competitive benefit. Some states are introducing limited requirements: Maine and Nevada now mandate general-purpose paid leave, and California, Colorado, Connecticut, and New York have paid sick leave laws. But a new starter at a US company has no guaranteed paid vacation time until their employer's policy grants it.
How US Vacation Accrual Typically Works
Where US employers provide vacation, it usually accrues one of two ways:
- Lump sum: All days granted at the start of the year (or employment anniversary)
- Per pay period accrual: e.g. 15 days/year = 1.25 days/month = 0.577 days per biweekly pay period
In California, accrued vacation is treated as earned wages — it cannot be forfeited and "use it or lose it" policies are illegal. In most other states, employers can require forfeiture of unused leave at year-end under a written policy.
EU: Working Time Directive (20-Day Minimum)
The EU Working Time Directive guarantees all EU workers at least 4 weeks (20 days) of paid annual leave. Member states can and do exceed this minimum — France mandates 25 days, Germany 20 days (with generous additional public holidays). The UK retained equivalent protections post-Brexit and enhanced them to 5.6 weeks (28 days) for full-time workers.
Calculating Pro-Rata for Mid-Year Starters and Leavers
When someone starts or leaves part-way through a leave year, entitlement is calculated pro-rata to the portion of the year they worked:
| Months worked | UK full-time accrued (28-day total) | US example (15-day policy) |
|---|---|---|
| 1 month | 2.3 days | 1.25 days |
| 3 months | 7.0 days | 3.75 days |
| 6 months | 14.0 days | 7.5 days |
| 9 months | 21.0 days | 11.25 days |
| 12 months | 28.0 days | 15.0 days |
Holiday Pay on Leaving
In the UK, workers must be paid for all accrued but untaken statutory holiday on termination. Daily rate = Annual salary ÷ 260 working days (for a standard 5-day-week employee). In the US, payout depends on state law — California requires full payout of accrued vacation; most other states allow forfeiture under a written policy. In France and Germany, unused leave must generally be paid out on termination.
Summary
The UK's 28-day statutory minimum (5.6 weeks × days worked per week) is among the most generous in the world. The US provides zero days by federal law — though most employers offer 10–15 days as a benefit. The EU guarantees 20 days, with most member states providing more via national legislation. For any pro-rata calculation, divide annual entitlement by 12 and multiply by months worked. Use our holiday entitlement calculator for instant results for any start date, working pattern, or country.