UK employers must retain annual leave and holiday pay records for six years

From 6 April 2026, UK employers must keep adequate records of annual leave and holiday pay and retain them for at least six years from the date they were made. Acas explains the requirement, including leave taken, carried-over leave and relevant payments. The change follows section 35 of the Employment Rights Act 2025.

Acas also states that records must be handled in line with UK GDPR. The requirement brings documentation, retention and access into the same review. Having a payroll system does not by itself explain which evidence is retained or how it can be retrieved.

Define the record before reviewing systems This editor recommends identifying which records demonstrate the employer’s leave and pay arrangements. The review should include source information, calculations, adjustments and approvals used in the process. Payroll and HR should agree ownership and how a correction is documented. A clear definition makes the retention policy easier to implement and check across different kinds of records.

Examine how information moves between systems and providers. A leave request may originate in one application while payment is calculated in another. The employer needs a method for relating those records, including after an employee leaves or a provider changes. Responsibility for retrieving evidence should be explicit in service arrangements, with a process for handling an unresolved request.

Test retrieval and control access This editor recommends testing a representative set of records rather than relying solely on a provider’s statement that data is stored. The team should locate the information, understand it and identify any missing component. The test can show whether a migration or manual adjustment has created a gap. Findings should be recorded so that a corrective action can be assigned and subsequently checked.

Retention should be reviewed alongside access and deletion controls. Decide who needs the information, how a request is authorised and what happens when the retention period ends. These decisions belong in a documented process followed across HR, payroll and outsourced services. The organisation should be able to explain how the process applies to the records it actually holds.

The immediate task is a reliable evidence trail for leave and holiday pay. A completed review should produce clear responsibilities, retrievable records and a plan for correcting identified gaps. Keeping those elements together makes the requirement an operational process rather than an untested statement in a policy.

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