Holiday Record-Keeping Requirements in the UK: Are Your Records Ready?

Since 6 April 2026, employers in England, Wales and Scotland must keep records that are adequate to show they have given workers their statutory holiday and holiday pay, and must retain each record for six years.

With most tribunal claims now carrying a six-month time limit, these holiday record-keeping requirements make complete, retrievable records more important than ever.

This guide assumes you already know the statutory holiday basics, so it focuses on what your records need to show. It is general information, not legal advice.

What Are the Holiday Record Keeping Requirements in the UK?

Employers must keep records that are sufficient to demonstrate compliance with the statutory holiday and holiday pay rules. The duty comes from section 35 of the Employment Rights Act 2025, which inserts a new regulation into the Working Time Regulations 1998 and has applied since 6 April 2026 (legislation.gov.uk).

Before then, most employers had no specific legal obligation to keep holiday records, although tracking leave was good practice. In practice, being able to show compliance means holding:

• Holiday taken: each worker’s leave, by date, including part-time, irregular-hours and part-year workers.
• Holiday carried over: balances brought forward from previous leave years.
• Holiday pay: what was paid for each period of leave and how it was calculated, including overtime, commission or bonuses where they count.
• Payments in lieu: pay for untaken holiday when someone leaves.

The format is up to you, provided it is reasonable, and the records are adequate. The new Fair Work Agency, launched on 7 April 2026, is taking on enforcement of holiday rights, and failing to keep adequate records is a criminal offence that can carry an unlimited fine (UK Employment and Pensions Hub).

How Long Do Employers Have to Keep Holiday Records?

Employers must keep each holiday record for six years from the date it was made. A record created in April 2026 therefore has to be retained until at least April 2032.

The duty applies to records created from 6 April 2026, but check your retention policy before deleting older holiday data, as it may still help you resolve an earlier dispute. Holiday records contain personal data, so store and secure them in line with UK GDPR.

What Changed for Tribunal Claims on 1 October 2026?

The time limit for most employment tribunal claims increased from three months to six months on 1 October 2026 (business.gov.uk). It applies where the complained-of act or dismissal occurred on or after that date. Earlier events keep the three-month limit.

Early conciliation extends the window further, so a claim can be brought close to 10 months after the event (Lewis Silkin via Legal 500). That is a long time for a manager to remember why leave was refused, which pattern a worker was on, or what a balance said on a given day. The record has to answer for them.

What Does an Adequate Holiday Record Look Like?

There is no official template. The practical test is whether you can show compliance for any worker on request. A defensible record answers five questions:

1. Which work pattern was the worker on at the time?
2. What leave did they request, and who approved it?
3. What leave did they take, and on which dates?
4. What were they paid, and how was it calculated?
5. Has anything changed since then, and by whom?

Payroll usually answers the fourth question. The others tend to sit across rotas, HR files and email, which is where gaps appear.

Why Do Spreadsheets and Disconnected Systems Struggle?

They rarely keep a history of what the data used to say. Three failure points come up most:

• Overwritten balances: a figure edited in place leaves no trace of the previous one.
• Lost pattern history: when a worker’s schedule changes, the pattern they were on before can disappear, making it hard to rebuild older entitlements.
• Scattered approvals: a manager’s agreement in an email thread sits away from the leave record it relates to.

Can You Produce These Five Records in Ten Minutes?

Pick one worker on variable hours and try. If any item takes longer than you would like, that is your gap.

1. Every period of leave they took in the last six months, with dates and approver.
2. Their opening and carried-forward balances for the current leave year, with the reason for any carry-over.
3. The work schedule they were on at a specific past date, including any change since.
4. How their last holiday payment was calculated, including variable pay.
5. A log showing who edited or approved their leave or timesheet records, and when.

How Does a Cloud-Based Time and Attendance System Help?

A cloud based time and attendance system keeps leave, schedules and hours in one place, so the history is there when you need it. Egress Systems has been trading for 23 years and has over 225 active software contracts. Focus, the software we supply, includes:

• Entitlement tracking: holiday balances for each employee and each team, including carry-forward and manual adjustments, through our absence management software.
• Change history: a record of what other users have changed in Focus.
• Locked records: approve and lock timesheets in our timesheet management software, and protect Focus from edits before a date you choose.
• Schedule history: work schedule date ranges let you change an employee’s schedule without affecting historical timesheets, and timesheets can handle multiple schedule changes in a single week.

Focus works alongside HR platforms including Sage HR, Iris Cascade HR, Breathe HR, Natural HR and XCD HR. Software does not make an employer compliant on its own, but it makes the evidence far easier to produce. For wider context, see our guide to managing annual leave and our overview of time and attendance software.

To see how Focus holds leave and hours history in one place, request a demonstration from Egress Systems.

FAQs

Do the Holiday Record Keeping Requirements Cover Zero-Hours and Part-Time Workers?

Yes. The duty covers the statutory holiday entitlement of workers, including part-time, zero-hours, and irregular-hours workers. Their records matter most because holiday pay for variable patterns is the hardest to calculate and to provide evidence for.

Is There a Required Format for Holiday Records?

No. The law lets you create and keep records in whatever manner and format you reasonably think fit. The records must still be adequate to demonstrate compliance and be retained for 6 years.

Does the Six-Month Tribunal Limit Apply to Events Before 1 October 2026?

No. The six-month limit applies where the relevant act or dismissal happened on or after 1 October 2026. Earlier events keep the three-month limit.

Do Holiday Records Have to Go Back Before April 2026?

The new duty applies to records made from 6 April 2026. Older records can still help in an earlier dispute, so review your retention policy before deleting anything.