News from OIP: Does a Federal-Only Holiday Count as a “Business Day”

October 13, 2025, is a paid federal holiday (Columbus Day), but state and county agencies do not have a paid day off (Discoverers' Day and Indigenous Peoples' Day are both statutorily recognized on the second Monday in October, but not as state holidays). The same is true for the annual federal Juneteenth holiday on June 19th (also statutorily recognized, but not as a state holiday). Because some deadlines under the Sunshine Law and the Uniform Information Practices Act (UIPA) are measured in business or working days, this can lead to questions about whether a federal-only holiday counts as a business or working day since the agency will in fact be open as usual during it.

Under the Sunshine Law, section 92-7.5, HRS, states that a board using a board packet must make it available to the public at least three full business days before its meeting. Section 92-7.5, HRS, expressly refers to section 11-1, HRS. This means that business days for distribution of a board packet are as defined in section 11-1, HRS, which excludes "Saturdays, Sundays, and state or federal holidays" from the definition of a business day (emphasis added). Thus, boards should treat a federal-only holiday the same as a state holiday for the purpose of calculating the board packet deadline: if there is an intervening holiday, the deadline falls one day earlier than it otherwise would.

For record requests, when calculating UIPA response deadlines under OIP's rules set out in chapter 2-71, HAR, a business day is defined as "a government agency business day" and excludes only "Saturdays, Sundays, and state holidays" (emphasis added). Thus, an agency should not add an extra day to its deadline to respond to a UIPA request when a federal-only holiday falls within the relevant period. An agency can still add an extra day to its response deadline when there is an intervening state holiday, however.

If you have questions about how to calculate Sunshine Law or UIPA deadline in your particular situation, you are welcome to contact OIP for further assistance.