If the bill designating 24 December as a public holiday is adopted, employers may face several related employment and payroll tasks. The change would affect working time schedules, the hours to be worked within a working time reference period, pay for work on public holidays, and the review of year-end schedules and annual leave arrangements already prepared.

The issue is particularly timely because, under the rules currently in force for the 2026 working calendar, Thursday 24 December is a rest day, with Saturday 12 December designated as a working day in exchange. Ministry for National Economy Decree 10/2025 (30 April) expressly provides for this arrangement for employees working a standard working pattern.

For employees working a standard pattern, working days and rest days are fixed by law: Monday to Friday are working days, while Saturday and Sunday are weekly rest days. As employers cannot unilaterally replace standard working days with Saturdays, national legislation is needed to reschedule these days on a mandatory basis to create extended weekends.

For employees who do not work a standard pattern, for example those whose hours are organised within a working time reference period, employers have greater flexibility to allocate working days and rest days independently of the calendar, subject to the strict requirements of the Labour Code.

What would it mean if 24 December became a public holiday?

A public holiday has a different legal status from a rest day. The Labour Code lays down specific rules on when ordinary working time may be scheduled on a public holiday. Under Section 102, this is permitted only in the cases specified by law, including employers or roles that by their nature operate on public holidays, seasonal or continuous operations, and certain services meeting essential public needs or supplied abroad. The Labour Code also defines in detail which employers and roles qualify as operating on public holidays by their nature.

Overtime is also restricted. On a public holiday, overtime may be required only from employees who may lawfully be scheduled to work ordinary hours on that day, or to avert serious emergencies specified by law.

Who may work on a public holiday?

A public holiday therefore does not mean a complete prohibition on work. Employers must nevertheless assess in each case whether the activity, employer or role meets the conditions set out in the Labour Code. This is particularly important where operations respond to a public need directly associated with the holiday, or where work remains necessary because the activity is continuous or seasonal.

Irrespective of the activity, changing 24 December from a rest day to a public holiday would not alter the general position for employees working a standard pattern, typically Monday to Friday: ordinary working time cannot, as a rule, be scheduled for that day.

For employees with uneven working time schedules and/or non-standard working patterns, however, employers will need to review schedules already prepared. In these cases, the employer currently determines whether 12 and 24 December 2026 are working days or rest days, within the framework of the Labour Code.

What pay is due for work on 24 December?

Employees who lawfully work on a public holiday are entitled to a 100% public holiday pay supplement. This is expressly provided for in Section 140(2) of the Labour Code.

When scheduling work for 24 December, employers must therefore consider both whether the work may lawfully be scheduled and whether the relevant payments are processed under the correct payroll categories.

A public holiday affects pay even where an hourly paid employee does not work

An important payroll consequence of introducing the public holiday concerns hourly paid employees and those paid on a performance basis. Under Section 146(1)(d) of the Labour Code, an employee is entitled to absence pay for their daily working hours where a public holiday falling on a standard working day reduces the hours they are required to work.

This means that a public holiday has payroll implications for an hourly paid employee even if they perform no work that day. Payment for the holiday is not remuneration for work performed, but statutory absence pay for the working time lost because of the public holiday.

It is therefore particularly important to distinguish the legal basis of the payment accurately. Absence pay is determined by the working time lost under a standard working pattern because of the public holiday, rather than by the hours actually worked. For a full-time employee, this is generally eight hours, regardless of the length of their usual shifts.

A different rule applies where an employee is unfit for work on the public holiday: they are entitled to 70% of their absence pay. No such absence pay is due if they receive statutory sickness benefit or occupational accident sickness benefit for that incapacity.

What happens to the working Saturday on 12 December?

Under the current rules, Saturday 12 December is a working day and 24 December is a rest day for employees working a standard pattern. The two dates therefore form a linked working day and rest day swap in the 2026 calendar.

If 24 December becomes a public holiday, the legal basis for the current swap would fall away. There would be no need to work on 12 December to compensate for a public holiday on 24 December. The 2026 working calendar would therefore also require legislative amendment to align the existing decree with the new statutory provision.

What happens to year-end working time schedules already prepared?

Many employers may already have prepared their year-end working time schedules, annual leave plans and other HR records by then. The legislative change would therefore create practical tasks as well.

Employers will need to review their December schedules, particularly the working days, rest days and annual leave allocated to 12 and 24 December. If annual leave has already been approved for 12 December, the records will also need to be corrected, as leave will no longer be required for what was previously a rescheduled working day.

Any changes to working time schedules already communicated must, of course, comply with the Labour Code's scheduling rules. Reviewing year-end arrangements therefore involves more than simply updating the calendar: the changes must be reflected in both employment administration and payroll.

Required hours may also change within working time reference periods

Introducing the public holiday requires particular attention where employees work within a working time reference period. Under Section 93(2) of the Labour Code, the hours to be worked during that period must be determined by reference to the standard working pattern, excluding public holidays that fall on standard working days.

If 24 December becomes a public holiday under the new rules, the hours to be worked within the reference period may need to be recalculated. This is particularly significant where the reference period has already started and the employer has already determined the required hours and employees' year-end schedules.

If the change takes effect, employers should therefore recalculate all affected reference periods and check that employees' required and actual working hours remain consistent with the new rules.

What should employers prepare for now?

A change during the year may also require updates to payroll and time-recording systems. Public holidays, rescheduled working days and rest days underpin numerous calculations in payroll calendars.

Once the legislation has been promulgated, employers should therefore check employment calendars, the status of 12 and 24 December, working time reference period calculations, public holiday absence pay for hourly paid employees, public holiday supplements, and attendance and other time-recording settings. The number of statutory working days in December will also fall from 22 to 21, which may affect pay amounts, for example in pro rata calculations for part of a month.

The change may also affect other employer calculations. One example is the social contribution tax relief for dual vocational training, where both the standard amount per working day and the number of eligible days are relevant. Transitional legislation and calculation rules may also need to be clarified in this area, as 2026 would have 252 working days rather than 253.

Designating 24 December as a public holiday would therefore affect several areas of employers' operations. Once the final legislation is published, a prompt and accurate response will depend primarily on applying its effects consistently across all relevant processes, from working time scheduling to payroll.