Annual Leave and Pay Records

The Employment Rights Act 2025 will come into force on 6 April 2026, introducing several changes with phased enforcement dates. One of the earliest measures - coming into effect this

April - is a new statutory requirement for employers to maintain adequate records of employees’ annual leave and holiday pay.

Despite its significance, this obligation has received relatively limited publicity and does not currently appear on the Government’s published implementation timeline. From 6 April, employers will be required to keep detailed records of annual leave taken and holiday pay provided for a period of six years.

While annual leave and pay calculations can be complex in some circumstances, many employers are likely to find that only a review of existing policies and procedures is needed to ensure compliance.

Enforcement of these recordkeeping duties will fall to the Fair Work Agency, which is scheduled to be formally established on 7 April. A factsheet has been published providing further

information about the role of this new body and its anticipated responsibilities.