Feriepenge in Denmark: How to Calculate and Pay Polish Rotational Workers 2026

Managing feriepenge, Denmark's statutory holiday pay system, is one of the most common compliance challenges for staffing agencies and construction companies employing Polish rotational workers. Unlike employees on permanent Danish contracts, rotational workers move between projects and employers, which makes tracking accrued leave entitlements and transferring funds accurately both critical and genuinely complicated. Getting it wrong can trigger claims through Arbejdstilsynet, Denmark's Working Environment Authority, and expose companies to significant financial liability. This guide walks you through every step of the process as it stands in 2026.

The Legal Framework: What Danish and EU Law Actually Require

Denmark's holiday pay rules are governed primarily by the Ferieloven (the Danish Holiday Act), which was substantially reformed and came into full effect in recent years, shifting the system to a concurrent holiday model. Under this framework, workers accrue paid leave simultaneously as they earn it, rather than waiting for the following year. The Act applies to all workers employed in Denmark, regardless of their nationality or country of residence, meaning Polish rotational workers on Danish worksites are fully covered.

At the EU level, the Working Time Directive (2003/88/EC) guarantees every worker a minimum of four weeks of paid annual leave. The Court of Justice of the EU has consistently reinforced in its CCOO ruling and subsequent case law that this entitlement cannot be waived or forfeited simply because a worker did not formally request leave. Employers cannot rely on administrative complexity as a defence for non-payment.

For Polish workers, understanding how Danish feriepenge interacts with their obligations under the Polish Kodeks Pracy (Labour Code) and any ZUS social insurance contributions is equally important, particularly for workers employed through Polish staffing agencies posted to Denmark under the EU Posting of Workers Directive.

Step 1: Establish Eligibility and Accrual Basis

Before calculating anything, confirm the worker's employment status. A Polish worker employed directly by a Danish company earns feriepenge at the statutory rate applied to their gross salary. A worker posted by a Polish agency must be checked against both the agency's home-country contract and Denmark's posting rules, which require that Danish minimum standards, including holiday pay, apply for the duration of the posting.

Under the Ferieloven, workers accrue 2.08 days of paid holiday per month of employment, totalling 25 days per full year. The holiday pay rate is calculated as a percentage of the worker's gross earnings during the accrual period. The current statutory rate is set out in the Ferieloven and administered through FerieKonto, the state-managed holiday pay account operated under the Danish Business Authority. Employers should verify the current applicable rate directly with the Danish Ministry of Employment at bm.dk, as rates and administrative procedures can be updated.

Step 2: Gather the Required Documentation

Accurate documentation is the foundation of a clean feriepenge process. For each rotational worker, you will need the full employment contract specifying the Danish worksite and period, payslips for every pay period worked in Denmark showing gross earnings, confirmation of the worker's Danish CPR number (personal identification number) or, where applicable, their foreign worker registration, and bank account details in the format required for international transfer if the worker will claim funds from Poland.

Polish workers who return home between rotations often find themselves needing to claim their accrued feriepenge from abroad. This is entirely possible through the FerieKonto system, but it requires that the employer has correctly reported and deposited the funds in the first place. Agencies managing large rotational teams may benefit significantly from moving away from spreadsheet-based tracking, a topic covered in detail in the guide on Excel to Digital System in a Staffing Agency: 2026 Guide.

Step 3: Calculate and Report Through FerieKonto

Danish employers are legally required to report and pay feriepenge contributions to FerieKonto on behalf of their employees. The reporting is done through the eIndkomst system, which is integrated with SKAT (the Danish Tax Authority). Every time you run payroll, the holiday pay contribution must be reported alongside income tax and ATP pension contributions.

For a hypothetical example: an agency employing 30 Polish rotational workers on a construction project, each earning a gross monthly wage, would calculate the holiday pay contribution for each worker individually based on their actual earnings that month, then submit the aggregated report through eIndkomst before the payroll deadline. The funds are held by FerieKonto until the worker chooses to take holiday or, under certain conditions, claims the balance at the end of the holiday year.

Detailed guidance on using the SKAT reporting portal is available directly at skat.dk.

Step 4: Handle the Transfer to Workers Based in Poland

When a Polish rotational worker completes their contract and returns to Poland, they have the right to claim any outstanding feriepenge balance. The worker must log in to the FerieKonto self-service portal using their NemID or MitID credentials, or, if they no longer have access to Danish digital identity tools, contact FerieKonto directly to initiate a manual claim process.

Employers play a key role here. If the worker's CPR number was correctly registered and all contributions were reported through eIndkomst, the claim process is straightforward. If there are gaps or errors in the reporting, the worker may face delays or shortfalls. This is also a moment where the worker's status under Polish ZUS insurance becomes relevant: holiday pay received from Denmark may need to be declared to Polish tax authorities depending on the applicable double taxation treaty. Workers should consult the ZUS portal at zus.pl or a cross-border tax adviser for guidance on their individual situation.

Step 5: Confirm Receipt and Close the File

Once the worker has submitted their claim and the funds have been transferred, the employer should retain documentation confirming that all feriepenge contributions were correctly paid and that no outstanding balance remains. This is particularly important given that Danish labour law allows workers to bring claims for unpaid holiday pay for a period after the employment ends. Maintaining clean records protects the employer in any subsequent audit or dispute.

For agencies managing end-of-contract procedures more broadly, the Terminating a Temp Worker in Denmark: Step-by-Step Guide 2026 provides a comprehensive checklist covering notice periods, final pay calculations, and documentation obligations under Danish law.

Common Mistakes That Cost Employers Dearly

The most frequent error is failing to register rotational workers in the eIndkomst system at all, particularly when they arrive mid-project or work short rotations. Every worker, regardless of how brief their Danish engagement, accrues feriepenge from their first day of employment. A second common mistake is using the worker's Polish bank account details incorrectly in the FerieKonto system, causing failed transfers and delayed payments that can quickly turn into formal complaints.

Employers also sometimes confuse feriepenge with the separate ATP (Arbejdsmarkedets Tillægspension) contribution, which is a pension supplement also mandatory for workers in Denmark. These are distinct obligations and must be reported and paid separately.

Finally, construction companies with mixed workforces should ensure that health and safety compliance is handled in parallel with payroll administration. Polish workers new to Danish sites must complete required induction training, a subject addressed in the guide on Mandatory Health and Safety Training for Polish Workers on Danish Construction Sites 2026.

Actionable Advice for 2026

Start every new rotational worker's file with CPR registration and eIndkomst enrollment on day one, not at the end of the project. Audit your payroll system quarterly to confirm that feriepenge contributions match gross earnings reported to SKAT. Brief your Polish workers at onboarding about how to access FerieKonto and claim their funds when they return home. And if your agency is still managing these processes in spreadsheets, the administrative risk grows with every worker you add. Building a reliable, auditable process now is far less costly than resolving claims and penalties later.