Feriepenge and Job Rotation: Holiday Pay for Polish Workers in 2026

Calculating feriepenge for a Polish construction worker who moves between Danish worksites every three months is one of the most misunderstood payroll tasks facing both Polish staffing agencies and Danish site managers in 2026. The core rules come from the Danish Holiday Act (Ferieloven), which was substantially reformed in 2020 to introduce concurrent holiday accrual, but the practical application for rotating or agency-placed workers still trips up even experienced HR professionals. Get it wrong, and you risk back-payments, complaints to Arbejdstilsynet, and damaged trust with your workforce.

Why Rotation Makes Feriepenge Complicated

Under the current Danish Holiday Act, employees earn paid holiday at a rate of 2.08 days per month of employment, adding up to 25 days per full year. The holiday is accrued and can be taken concurrently during the same year it is earned. For a worker who stays with one employer for a full calendar year, this is straightforward. For a Polish worker who joins a construction project in January, finishes in March, moves to a second site under a new contract in April, and then rotates again in July, the picture becomes far more fragmented.

Each employment relationship generates its own feriepenge entitlement. When the employment ends, the employer must either pay out the accrued holiday pay directly or transfer it to FerieKonto, the state-administered holiday pay fund run by the Danish tax authority Skat. The worker can then draw on those funds during a later holiday period, even if they are working for a completely different employer at the time. This system was designed precisely to protect mobile workers, but it only works correctly if every employer in the chain fulfils their reporting and payment obligations.

Step 1: Confirm Eligibility and Employment Status

Before any calculation begins, you must be clear about the legal basis of the work. A Polish worker placed by a Polish staffing agency (vikarbureau) on a Danish construction site may be employed directly by the agency, by a Danish user company, or under a posted-worker arrangement governed by EU Directive 96/71/EC on the posting of workers. The employment relationship determines who is responsible for calculating and paying feriepenge. If the agency is the formal employer, the obligation sits with the agency. If the Danish construction firm has taken the worker on directly, the obligation is theirs. Misidentifying this point is one of the most common and costly mistakes in the sector. For a broader look at how contracts between Polish agencies and Danish clients should be structured to avoid exactly this confusion, see Vikarbureau w Danii: Legal Contracts with Danish Clients 2026.

Step 2: Gather the Required Documents

For each employment period at each worksite, you will need the signed employment contract or posting letter, payslips covering every month of work, and documentation of the exact start and end dates. Danish employers are legally required to keep detailed records of working time, a requirement enforced through LOV 89 and monitored by Arbejdstilsynet. If records are incomplete, calculating the correct feriepenge base salary becomes guesswork, and guesswork is not acceptable to Skat. For a detailed breakdown of what records must be kept and for how long, the Archiving Work Time Records Under LOV 89: 2026 Guide covers the obligations precisely.

Step 3: Calculate the Feriepenge Amount

Under the Danish Holiday Act, feriepenge is calculated as 12.5 percent of the employee's total earned wages during the accrual period. This percentage applies to gross pay including any supplements, overtime pay, and bonuses. For a rotating worker, you calculate this figure separately for each employment period. Consider a hypothetical example: a worker employed for three months at a gross monthly wage earns a certain total; 12.5 percent of that total is the feriepenge owed for that rotation. When the employment ends after three months, the employer must report and pay this amount to FerieKonto via the Skat portal at skat.dk. The worker is then issued a statement showing their available holiday pay balance.

One point that frequently causes errors: overtime and irregular bonuses must be included in the calculation base. An employer who calculates feriepenge only on the basic contractual wage and excludes weekend supplements common on construction sites is under-reporting, which can trigger a demand for back-payment with interest.

Step 4: Report and Transfer to FerieKonto

The practical submission happens through the employer's account on the Skat business portal. The employer registers the worker's Danish personal identification number (CPR number) or, for newly arrived workers who do not yet have a CPR number, coordinates with Skat to ensure the payment is correctly attributed. Payments must be made promptly after the employment ends; the Danish Holiday Act sets specific deadlines that vary depending on when in the holiday year the employment terminates. Delays attract interest charges, so building the transfer into the standard offboarding checklist for each rotation is strongly advisable.

Polish agencies operating in Denmark should also be aware of their parallel obligations under Polish law. Workers who are formally employed by a Polish entity and posted to Denmark retain certain rights under the Polish Kodeks Pracy (Labour Code) and may have contributions running through ZUS (the Polish Social Insurance Institution) simultaneously. The interaction between Danish feriepenge and any Polish holiday entitlement must be managed carefully to avoid double accrual or gaps in coverage. The PIP (Państwowa Inspekcja Pracy, the Polish Labour Inspectorate) can provide guidance on the Polish side of these obligations at pip.gov.pl.

Step 5: The Worker Claims Their Feriepenge

Once funds are held at FerieKonto, the worker can claim them during a holiday period through the self-service portal at jobnet.dk or directly through FerieKonto's own interface linked from the Skat website. For Polish workers who return to Poland between rotations, they can still access their Danish feriepenge remotely, provided they have their NemID or MitID digital identification credentials active. Ensuring workers set up and maintain their MitID before leaving Denmark at the end of each rotation is a small administrative step that prevents significant frustration later.

Common Mistakes to Avoid

The most frequent error is treating a rotating worker as if they are a single continuous employee across multiple contracts when in legal terms each contract creates a separate accrual period with its own reporting obligation. Related to this, some employers incorrectly defer the FerieKonto transfer until the end of the calendar year rather than at the end of each employment contract. A third common problem is failing to account for public holidays and sick days correctly when determining the accrual base, particularly for workers who were absent for part of a rotation due to a workplace injury. On that note, employers should also be familiar with their broader obligations when incidents occur on site, as explored in Workplace Accident in Denmark: Who Is Liable and What Steps Must a Polish Agency Take in 2026.

Actionable Advice for 2026

Build a simple rotation checklist that triggers automatically at the end of every three-month contract: verify the total gross pay figure including all supplements, calculate 12.5 percent, submit the FerieKonto transfer through the Skat portal, issue the worker a written statement of the amount transferred, and confirm the worker's MitID credentials are active. Keep copies of all payslips and contracts for at least five years in line with Danish record-keeping requirements. If you manage multiple rotating workers simultaneously, a shared payroll calendar flagging each contract end date will prevent transfers from slipping through the cracks. When in doubt about the interaction between Danish and Polish obligations for a specific worker, consult the official guidance available at zus.pl and the Danish Ministry of Employment resources at bm.dk before making a decision.