More than 1 million British workers are missing out on holidays, or being cheated out of time off, research has revealed.

There is no good reason why UK workers should have the lowest paid holiday rights in the EU

John Monks, TUC

Analysis of government figures shows that more than 400,000 UK workers were receiving fewer than 12 days paid holiday a year, the Trades Union Congress (TUC) said.

A further 850,000 Britons are missing out on time off because of a loophole in the working time regulations, which means employers can count bank holidays as part of workers' the minimum holiday entitlement.

UK workers are entitled to a minimum of 20 (working) days annual leave, but must rely on the generosity of their employers for entitlement to the UK's eight bank holidays.

In Germany, workers are allowed 32 days, in France 36 and in Austria 38, the most generous allowance among EU countries.

'Prosperous country'

TUC chiefs claimed their analysis represented the first illustration of the effects of the loophole, which they would campaign to close.

We all like the idea of more time off, but most people understand that can't come without cost

Digby Jones, CBI

The TUC wants workers to be entitled to a minimum of four weeks paid leave a year, plus 11 paid bank holidays - a total of 31 days.

The entitlement would apply to part-time workers on a pro-rata basis.

John Monks, general secretary of the TUC, said: "There is no good reason why UK workers should have the lowest paid holiday rights in the EU.

"We are a prosperous country and can certainly afford to raise our minimum standards.

"Indeed, there is evidence that more holidays and increased productivity go hand in hand. "

Employees in the North East, Midlands and Yorkshire and Humberside, Northern Ireland and Wales are least likely to be given their full holiday entitlement, Friday's report said.

Workers in the South East, London, Scotland and the North West are least likely to lose out.

Bosses' defence

The CBI denied workers were being cheated out of their holiday rights.

It said the average UK employee got five days more than the legal entitlement of 20.

Director general Digby Jones said: "Bank holidays may not be a legal right but the overwhelming majority of UK employers give them in addition to annual leave.

"We all like the idea of more time off, but most people understand that can't come without cost."

The Department of Trade and Industry said that both France and Sweden allowed employers to offset some public holidays against the minimum holiday entitlement.

It said that including bank holidays in the 20 days leave was a "legitimate option" for employers.

"Any move to increase the number of bank holidays, or make them a statutory entitlement, would have to be balanced against the inevitable cost and disruption to industry," said a spokesman.

Further information:

Advice on working time and holiday rights, are available on the Acas, TUC and DTI websites.

The TUC has a "Know your rights" helpline (0870 600 4 882) - open between 8am to 10pm. Calls are charged at the national rate.