Holiday records from 6 April 2026: what employers in Great Britain must keep, and for how long
Where this applies: Great Britain (England, Wales and Scotland). The regulations below are marked as extending to England, Wales and Scotland on legislation.gov.uk. Northern Ireland has separate holiday rules and is not covered. Not legal advice.
Since 6 April 2026 the Working Time Regulations 1998 have contained an express duty to keep holiday records. It is regulation 16B, inserted by section 35 of the Employment Rights Act 2025 and brought into force on 6 April 2026 by regulation 3(8) of S.I. 2026/323, which lists “Section 35 (duty to keep records relating to annual leave)”.
What regulation 16B says
Regulation 16B(1): an employer must “(a) keep records which are adequate to show whether the employer has complied with the entitlements conferred by regulations 13(1), 13A(1), 15B(2) and 16(1) and the requirements in regulations 14(2) and (6) and 15E(2); (b) retain such records for six years from the date on which they were made.”
Regulation 16B(2): the records “may be created, maintained and kept in such manner and format as the employer reasonably thinks fit.” There is no prescribed form.
GOV.UK’s holiday pay page puts it this way: employers “must keep detailed records of annual leave and holiday pay for a minimum of 6 years from the date they were made. For example, they should document the number of annual leave days taken and how much holiday pay is paid.”
What the records have to show
| Regulation | What it covers |
|---|---|
| 13(1) | Four weeks’ annual leave in each leave year. |
| 13A(1) | Additional leave: 1.6 weeks for leave years from 1 April 2009. Together with reg 13 this is subject to “a maximum of 28 days” (reg 13A(3)), the 5.6 weeks GOV.UK describes. |
| 15B(2) | Irregular-hours and part-year workers, leave years beginning on or after 1 April 2024: leave accrued in the year, plus leave carried forward, less leave taken. See 12.07% accrual. |
| 16(1) | Payment for leave “at the rate of a week’s pay in respect of each week of leave”. See the 52-week average. |
| 14(2) and (6) | Payment in lieu for workers whose employment ends part-way through the leave year (regular-hours workers). |
| 15E(2) | Payment in lieu of untaken leave for irregular-hours and part-year workers who leave. Under reg 15E(5) it does not apply to leave already paid as rolled-up holiday pay. |
A practical checklist
The regulations don’t list fields. Working back from what has to be shown, a record for each worker and leave year would usually let someone see:
- the leave year dates and whether the worker is regular-hours or irregular-hours/part-year (the method depends on it, see reg 15F);
- the entitlement, or the leave accrued pay period by pay period, and any leave carried in;
- leave taken (dates and hours or days) and the balance;
- holiday pay paid for each period of leave, and how it compares with a week’s pay;
- for leavers, the leave untaken at the termination date and the payment in lieu made.
Because the six years run “from the date on which they were made”, it helps to date each record and keep it with the employer’s payroll records.
What Leaveproof does
- Builds a records pack for each leave year from the payroll export and the optional leave sheet: per worker, the type and method, leave carried in, entitlement or 12.07% accrual, leave taken, balance, 52-week average weekly and hourly pay, and the checks that apply. The pack is a CSV plus a print-to-PDF page showing the date to keep it until, six years after it was made.
- Makes a holiday pay detail CSV and an exceptions CSV: holiday paid below the 52-week average, rolled-up holiday pay below 12.07%, gaps in the payroll record, unexplained carry-over, leave left at year end and leavers who may be owed pay in lieu, each with the regulation it relates to.
- Runs in your browser. Payroll and leave data are not uploaded.
Leaveproof reads a payroll export saved as CSV, one row per worker per pay period (or per pay item), plus the employer’s leave sheet if there is one. It is designed for exports from Xero Payroll UK and BrightPay, but their report columns are chosen by the user and have not been checked against every layout, so Leaveproof shows the columns it detected and asks you to confirm which is which before it works anything out. It remembers that choice for each employer. Any payroll software that can export pay periods, pay, hours and holiday columns to CSV can be used the same way.
What it doesn’t do
- It doesn’t store the records for you. You save the files and keep them for the six years.
- It applies the statutory minimum only: contractual extra leave and contract bank-holiday rules are not covered, and it doesn’t decide which carry-over exception applies. It flags these for you to check.
- It doesn’t calculate leave accrued during sick or statutory leave (reg 15C); it flags it.
Try it on your own payroll export. Free, no account or sign-up, nothing uploaded: it runs in your browser. The Free plan covers one employer and the first 5 workers (by worker ID) in the records pack and exceptions. Standard ($19 per month or $190 per year) covers every worker for one employer; Bureau ($49 per month) covers any number of employers: see pricing.
Make a records packMore guides
- 12.07% holiday accrual for irregular-hours and part-year workers
- Rolled-up holiday pay: the 12.07% uplift and who it can be used for
- Holiday pay 52-week average: weeks with no pay and the 104-week look-back
- Holiday pay when someone leaves: payment in lieu of untaken leave
- Carrying over holiday to the next leave year
Not legal advice. This guide summarises the statutory minimum rules in the Working Time Regulations 1998 as they apply in Great Britain (England, Wales and Scotland), checked against legislation.gov.uk and GOV.UK on 27 October 2026. Contracts, collective agreements and individual cases can change the answer; take advice on a specific case. Leaveproof is independent and not affiliated with or endorsed by Xero or BrightPay. Xero is a trademark of Xero Limited; BrightPay is a trademark of Bright Software Group.