Holiday records: what to keep, and for how long.

The Employment Rights Act 2025 added regulation 16B to the Working Time Regulations. Since 6 April 2026, employers must keep records good enough to show they have complied with the rules on holiday entitlement and holiday pay, and keep each record for six years from the date it was made.

It covers all workers, including irregular-hours and part-year workers.

Acas lists:

• the holiday each person has taken;
• holiday carried over from earlier years;
• holiday pay, and what it included, such as overtime, bonuses or commission;
• any payment instead of holiday, such as for holiday not taken when someone leaves.

To show the entitlement was right, keep what it was worked out from too: their working pattern and, for irregular-hours staff, the hours they worked.

You can keep them in whatever way and format you reasonably think fit, on paper or electronically. What matters is that you can find and show them for any person over the last six years, including people who have left.

The Fair Work Agency, set up on 7 April 2026, enforces holiday pay and the duty to keep records. Acas says it can demand underpaid holiday pay and impose financial penalties, and that failing to show records exist could be a criminal offence.

• Check where each part lives: leave in one place, holiday pay usually in your payroll.
• Make sure leavers’ records are kept, not deleted with their account.
• Try producing one person’s six years now, before anyone asks.