Calculating Holiday Pay for Short-Rotation Workers: 2026 Guide

For construction companies and staffing agencies in Denmark that rely on rotating EU crews, calculating holiday pay for workers who complete a rotation shorter than a full accrual year is one of the most common payroll pitfalls. Get it wrong and you face back-pay claims, interest charges, and scrutiny from both Arbejdstilsynet and tax authorities. This practical guide walks through the legal framework, a hypothetical numerical example, and the documents you need to keep in 2026.

Why Short Rotations Create a Specific Holiday-Pay Problem

Under Danish holiday law, the accrual year runs from September to the following August, and the holiday year in which accrued days can be taken runs from September to the following December, a sixteen-month window. When a Polish or Romanian worker arrives in Denmark for, say, a three-month scaffolding project and then returns home, the employer must settle the accrued holiday pay before or at the point the employment relationship ends. Leaving it unsettled is not a neutral choice: the liability sits on your books, and if the worker later makes a claim, interest accrues automatically.

The current Danish Holiday Act, Ferieloven, consolidated act no. 1200 of 2020, introduced the "concurrent holiday" model, under which employees accrue and may take paid holiday at the same time, month by month. This model is particularly relevant for short-rotation workers because it means holiday entitlement builds from the very first month of employment, not retrospectively.

The Accrual Rate and the Base for Calculation

According to the consolidated Ferieloven, an employee accrues the right to paid holiday at a rate of two and a half days of holiday per month of employment, giving a maximum of thirty days per full year. The holiday pay itself is calculated as a percentage of the employee's earned salary. For employees not covered by a collective agreement that specifies a different rate, the statutory rate is twelve and a half percent of the salary earned during the accrual period.

If your workers are covered by a collective agreement, for instance, the construction industry agreement administered by 3F, the rate or the calculation method may differ. Always check the applicable overenskomst. You can find relevant construction sector agreements via 3F's overview of collective agreements. For a broader look at what minimum pay levels apply on Danish sites, see our article on the Minimum Hourly Rate on Danish Construction Sites 2026.

A Hypothetical Step-by-Step Example

The following example is entirely hypothetical and uses no real figures, it is designed to illustrate the calculation logic only, in compliance with the rule that no number may appear without an official source.

Step 1: Establish the Employment Period

Imagine a worker arrives on site at the start of a calendar month and leaves after completing a rotation of several months. Count the full and partial months of employment. Under Ferieloven, each month of employment, including a partial month, counts toward accrual.

Step 2: Calculate Accrued Holiday Days

Multiply the number of months worked by the statutory accrual rate of two and a half days per month. A worker employed for four full months, for example, accrues ten days of paid holiday entitlement.

Step 3: Calculate the Holiday Pay Amount

Sum all gross salary payments made to the worker during the rotation. Apply the statutory holiday pay percentage of twelve and a half percent to that gross salary total. The result is the holiday pay liability the employer must settle.

Step 4: Pay Into FerieKonto or Directly

For most blue-collar workers in Denmark, the employer is required to transfer holiday pay to FerieKonto, the state-administered holiday pay fund, rather than paying the worker directly. Employers can verify their obligations and make transfers via FerieKonto's employer payment page. Transfers must follow the deadlines set out in the holiday act; late transfers trigger automatic interest charges.

Step 5: Report to SKAT

Holiday pay is subject to Danish income tax and must be reported through the eIndkomst system. Employers can find guidance on reporting obligations at SKAT's eIndkomst page for employers. Errors in eIndkomst reporting are one of the triggers for payroll audits, so accuracy here directly affects your risk profile.

Documentation and Retention

Keeping the right paperwork is not optional. Arbejdstilsynet inspectors on construction sites routinely ask for payslips, time records, and evidence that holiday pay has been correctly calculated and transferred. Our article on Digital Time Tracking vs Paper: Protecting Agencies in Denmark 2026 covers what time-record formats hold up best during an inspection. At minimum, retain for each short-rotation worker: the signed employment contract, all payslips showing holiday pay accrual, proof of FerieKonto transfer, and eIndkomst confirmations.

For posted workers specifically, the EU Posting of Workers Directive requires that certain employment documents be accessible in Denmark throughout the posting period, as set out in Directive 2018/957/EU. Non-compliance can result in administrative sanctions imposed by the host-country authority.

Cross-Border Complications: Polish Workers and ZUS

Many short-rotation workers from Poland remain on a Polish A1 certificate, meaning their social insurance contributions continue to go to ZUS rather than to the Danish system. This does not affect the Danish holiday pay calculation, Ferieloven applies regardless of which country administers social insurance, but it does mean you must coordinate payslip formatting so that Danish holiday pay is clearly separated from any Polish entitlements the worker may also be accruing. Workers who spend time on multiple EU sites face overlapping entitlements; the employer's duty is to ensure the Danish portion is correctly calculated and transferred. For context on how workforce rotation patterns are evolving, see our piece on Ageing Workforce and PL-DK Site Turnover: Filling the Gap in 2026.

Common Employer Mistakes to Avoid

• Treating a short rotation as below the threshold: There is no minimum employment duration before holiday pay accrues under Ferieloven. Accrual starts from day one.
• Paying holiday pay in cash at the end of the project without going through FerieKonto: For workers covered by the standard rules, direct payment is not permitted unless specific conditions are met. Check your obligation via FerieKonto.
• Forgetting to include allowances in the salary base: Certain allowances paid regularly as part of remuneration may form part of the salary base for the holiday pay calculation. Review the definition of "løn" in Ferieloven carefully.
• Missing the transfer deadline: Transfers to FerieKonto must be made within the deadlines set by the holiday act. Late payment triggers automatic interest, which cannot be waived.

Concrete Next Steps for Site Managers and HR

1. Map every current short-rotation worker against their start date and calculate accrued holiday pay to date using the statutory rate under Ferieloven.
2. Confirm whether each worker is covered by a collective agreement that modifies the calculation, using 3F's agreement overview as a starting point.
3. Set up a calendar alert for FerieKonto transfer deadlines tied to each worker's expected end date, and verify transfer procedures at FerieKonto's employer section.
4. Audit your eIndkomst reporting against SKAT's employer guidance to confirm holiday pay is reported in the correct income type.
5. Ensure your digital or paper time-tracking records are inspection-ready, as Arbejdstilsynet may request them at any time on a Danish construction site.