Keeping holiday records

New requirement

Since 6 April, the Employment Rights Act 2025 requires employers to keep 'adequate' records to demonstrate their compliance with their workers' right to paid annual leave under the Working Time Regulations.

What must you record?

You must keep records for all staff (including any 'irregular hours' or 'part-year' workers), showing:

  • That they received the ordinary and additional annual leave they're entitled to (i.e. if working full time this will be 20 days ordinary leave and 1.6 weeks or 8 days additional leave)
  • Any annual leave that they carried over from previous years (e.g. due to sickness or being on a type of statutory family leave)
  • That they're paid correctly when they take annual leave (this may need to include information about how their pay has been calculated, such as what payments have been included in the calculation, e.g. commission or overtime payments)
  • Any payments made in lieu of unused holiday on termination of employment, including leave carried over from a previous year.

How must the information be recorded?

You can record and maintain the information in any format (there's no requirement for it to be kept or stored in any particular way). However, you must retain the records for 6 years from the date on which they were made, and manage it in line with GDPR.

What happens if you don't comply?

Failing to record the information will be a criminal offence (resulting in a fine).

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