The Holidays Act is complex, and non-compliance is common

By Equipo Saplic Published on 12/08/2026 Updated on 12/08/2026

Which is why checking your holiday pay is worth the effort.

In this guide
  1. The compliance problem
  2. Annual holidays
  3. Final pay and holidays
  4. Reform is under discussion
  5. What to check
  6. If you think it is wrong
  7. Records

Leave entitlements in New Zealand are governed by the Holidays Act 2003, and it is widely acknowledged to be complicated.

The compliance problem

Commentary on New Zealand employment law notes that unintentional non-compliance with the Holidays Act is common and compliance costs are high, largely because the Act does not map neatly onto modern work patterns.

That is unusual to see stated openly, and it means checking your own holiday pay is worthwhile rather than paranoid.

Annual holidays

Employees are entitled to paid annual holidays under the Act, with the calculation depending on your pattern of work and earnings.

For employees with regular hours and pay, the calculation is straightforward. For those with variable hours, commission or irregular patterns, it is where errors concentrate.

Final pay and holidays

Compensation for unused annual holidays must be included in your final pay, provided on or before the pay day for the final pay period.

Reform is under discussion

Changes to the Holidays Act have been proposed to align it better with modern work practices. Commentary suggests the complexity is unlikely to be fully resolved, and that transitioning to a new Act with new payroll systems will be a significant exercise for employers.

If you are reading guidance on holiday pay, check whether it reflects the current Act.

What to check

  1. That your holiday pay calculation accounts for your actual earnings pattern, not just base salary
  2. That commission, overtime and allowances were included where they should be
  3. That unused holidays appear separately in your final pay breakdown

If you think it is wrong

Raise it with your employer. Employment New Zealand provides free guidance on 0800 20 90 20.

Remember the 90-day personal grievance window if the issue relates to a dismissal, though pay claims can follow a different route.

Records

Employers retain records for at least six years. Keep your own payslips — for variable earners especially, they are the evidence of what should have been included in the calculation.

Frequently asked questions

Why is holiday pay often calculated wrongly?
The Holidays Act is widely acknowledged as complex and does not map neatly onto modern work patterns, so unintentional non-compliance is common.
Where do errors concentrate?
Among employees with variable hours, commission or irregular patterns, where the calculation is more involved than for regular salaried staff.
Is unused holiday paid at termination?
Yes. Compensation for unused annual holidays must be included in final pay, provided on or before the pay day for the final period.
Is the Act changing?
Changes have been proposed to align it with modern work practices, though commentary suggests the complexity is unlikely to be fully resolved.
What should I check?
That the calculation accounts for your actual earnings pattern rather than just base salary, and that commission, overtime and allowances were included where they should be.

Sources

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