Working time and leave

Hello, can someone help me in this query, the company i work for has recently changed the way our 4 weeks annual leave is counted. They have now said that the first 4 weeks leave including bank holidays will be classed as statutory leave, which means that 48 hours will be recorded against us, any additional leave will be non stat leave which will record zero hours. Until recently my manager has been moving stat and non stat leave about so as to allow us to work more hours as overtime, (this has of course been agreed)., and has not attracted any notice from Vosa or any other agency. Therefore was he breaking the law in the first place? As some of my colleagues think that this has been changed so as to reduce earnings. If it helps our reference period in 26 weeks, and many of our drivers work long hours by agreement, and we do not work Bank Holidays.

The rule is that the first 4 weeks/20 days must be counted for RTD but not necessarily as 4x48 hours

If the whole of a fixed week is holls then its 48 hours but if say 5 days in a fixed week are taken as holls and 1 day is worked then the 5 days holls count as 5x8 hours