From 6 April, new holiday recording rules requires employers to retain detailed records of holiday pay and leave for a minimum of six years from the date they are created. This applies to all workers, including part-time and those on irregular hours. It also covers key areas such as leave taken, carry-over, and any payments in lieu.
In this article, we break down what these changes mean in practice, outline the specific records you must keep, and share practical steps to help you remain compliant.
Information you are required to record
From 6th April 2026, employers are now legally required to record:
Employers must record:
- holiday staff have taken
- holiday pay
- holiday carried over from previous years
- any payments in lieu of holiday. An example of this is pay for an unused holiday when someone has left a job
When it comes to holiday pay, you must give details of what is included. This includes bonuses or commission. These records must be retained for at least 6 years from the date they were made.
How to keep holiday records
There is flexibility in how employers store and manage these records. They may use any system that is practical, secure, and allows for easy access when needed. Common methods include:
- Digital HR or workforce management systems
- Payroll software
- Spreadsheets or databases
Many employers may already use systems that capture some or all of this information. However, it is their responsibility to ensure that these systems record all the details required by law.
Data protection requirements
All holiday and pay records must be handled in accordance with UK data protection legislation, including UK GDPR. This means employers must:
- Keep records secure and protected from unauthorised access
- Only collect and retain necessary information
- Ensure data is accurate and up to date
If you fail to follow new holiday entitlement rules
It could be a criminal offence ff you are unable to prove you have holiday records. The newly formed Fair Work Agency will have enforcement rights.
You will likely face unlimited fines, additional financial penalties, and demand for underpayment of holiday pay.
How Breathe HR Can Help With New Holiday Recording rules
Keeping accurate holiday records manually can quickly become time-consuming and prone to error, particularly with the new requirement to retain records for six years. This is where a system like Breathe HR can make a real difference.
Breathe HR allows you to centralise all holiday and leave data in one place. Employees can request leave directly through the system, while managers can approve or decline requests with full visibility of remaining entitlement. The system automatically tracks:
- Holiday entitlement and accrual
- Leave taken and booked
- Carry-over between holiday years
- Payments in lieu (where applicable)
Because everything is recorded digitally, you have a clear audit trail that can be accessed at any time. This makes it much easier to demonstrate compliance if required and removes the risk of lost or incomplete records.
How We Can Support Your Setup
Implementing a system is one thing, but ensuring it works properly for your business is another.
We support clients with the full setup and optimisation of Breathe HR, including:
- Configuring holiday rules in line with legislation and your contracts
- Setting up different leave types (including irregular hours arrangements)
- Ensuring accurate calculations for part-time and variable hours staff
- Uploading employee data and historical records where needed
- Training managers and employees on how to use the system effectively
We also provide ongoing support to make sure your processes remain compliant as legislation evolves. This means you are not only meeting your legal obligations, but also saving time and reducing administrative burden across your business.
How The HR Booth can help
Navigating changes to employment law can be challenging, especially when new requirements introduce additional administrative responsibilities.
At The HR Booth, we work closely with businesses to ensure they remain compliant while implementing practical, efficient HR processes. Whether you need support reviewing your current systems, implementing new software, or training your team, we are here to help.
Get in touch with us today to find out how we can support your business with the new holiday recording rules and wider HR compliance. To find out when other changes will be made as part of the employment rights bill, download your free employment rights bill roadmap.
