City begin a run of four games in 12 days - including back-to-back home games against Liverpool and Crystal Palace on Boxing Day and December 28 - at Fulham on Saturday.
Pellegrini accepts such a programme is traditional in the English game but the Chilean remains a firm fan of the winter breaks he has was accustomed to elsewhere.
The Chilean, who was appointed by City in the summer after nine years managing in Spain, said: "It is very important, here in the Premier League, all these days like Boxing Day.
"But all the other countries stop and I think it is very important for the players to have a winter break because they play too much, too many games.
"We have to play the 26th and the 28th, less than 48 hours. It is incredible that the games are so near.
"I think that to play two games in less than 72 hours is not a good thing, the players are not recovered in less than 72 hours normally.
"Playing after 40 hours, I think, is a very bad thing. It is a lot of games and in this case we are not in the best situation."
City, who have already played six games in December, may have reason to fear more damage after losing key players Sergio Aguero and Pablo Zabaleta to injury in the past week.
One man who will hope to fill that gap is Edin Dzeko, who staked his claim for a regular start with two goals in the Capital One Cup quarter-final win at Leicester in midweek.
Dzeko has often had to be content with a place on the bench this season due to the form of Aguero and Alvaro Negredo.
Pellegrini said: "I always try to involve all the players in what we are doing every week.
"After that, I must choose 11 starters but all the other players have exactly the same importance and I think Edin Dzeko is working every day very well.
"He couldn't play more because Sergio and Alvaro were scoring goals and the team was playing well but you saw last Tuesday that he played and he scored two goals.
"He can play often now. He was always an important player for the team."