Holiday entitlement under the Working Time Regulations 1998 applies uniformly across England, Wales, and Scotland, so the 5.6-week floor and the notice mechanics do not change as you cross a border. The practical differences sit in the public holidays. England and Wales observe eight bank holidays, Scotland has its own pattern including 2 January and St Andrew's Day, and Scottish employers should make sure their form's leave-year calculation reflects whichever bank holidays the contract treats as paid leave rather than assuming the English calendar.
Northern Ireland is the genuine outlier. Holiday rights there flow from the Working Time Regulations (Northern Ireland) 2016 rather than the 1998 Regulations, though the headline 5.6-week entitlement is the same. Northern Ireland also observes additional bank holidays, including St Patrick's Day and the Battle of the Boyne, which means a form designed for a Belfast workforce should account for up to ten bank holidays when reconciling the annual balance. Using a Great Britain bank-holiday count for a Northern Ireland employee will understate or overstate the remaining entitlement.
Across all four nations the Equality Act 2010 (or its Northern Ireland equivalent) sits behind the leave process. Refusing or clawing back leave in a way that disadvantages someone connected to a protected characteristic, such as religious observance dates, can expose an employer to a discrimination argument. The form helps here by recording a clear, operational reason for any refusal. When a request shades into family leave rather than ordinary holiday, our UK Section 1 written statement of particulars template clarifies which entitlements the contract already promises.