Employment & immigration — The explainer

Holiday records needed to explain how the balance was reached

A recordkeeping duty for annual leave and holiday pay took effect in April 2026. A balance alone could not provide the full trail; employers needed organised inputs, corrections and access arrangements across recruitment and payroll support.

A records administrator and payroll colleague review anonymised holiday and hours folders from an archive.
AI-generated concept photograph illustrating this recruitment topic. It is not a historical photograph and does not show Key Med staff, clients or premises.

The recordkeeping duty that commenced

The new duty required records adequate to show compliance with the relevant holiday entitlements and payments, retained for six years. Acas guidance identifies information such as leave taken, carry-over, holiday pay and payments in lieu. Employers could choose a reasonable format; a particular software product was not prescribed.

The obligation to keep records was distinct from the staged introduction of Fair Work Agency holiday-pay enforcement. Employers should not treat a later enforcement timetable as permission to postpone the recordkeeping duty. The responsible HR and payroll owners needed to establish what information their process should retain.

The history behind a leave balance

A current holiday balance can conceal earlier adjustments, late timesheets or a payment made when an assignment ended. If an employer later needs to review the position, it may require the inputs and approved changes behind that number. Overwriting old values without a trace can make reconstruction unnecessarily difficult.

Retention also needs access controls and a defined process for corrections. The instruction to keep relevant records does not justify copying every document into several unrestricted folders. A coherent record should connect the worker, applicable period, underlying inputs and approved outcome, with a responsible owner for the system.

A reconciliation schedule can identify which records come from timesheets, payroll and the leave system, helping the client spot gaps between otherwise complete-looking datasets.

Keep a usable calculation trail

Key Med Solutions can help organise a client-approved record inventory, reconcile missing timesheets and identify where leave information is split between systems. The client and its advisers should determine the legal content and retention approach. Administrative staff can then follow the approved procedure and flag exceptions.

A useful spot check asks whether an authorised reviewer can trace a sample payment back to its relevant hours and instructions. If the trail breaks, the exception should show which input is missing and who must resolve it. The check supports record quality; it does not independently certify a holiday-pay calculation.

The April 2026 lesson is to retain a usable history, not merely a larger archive. Key Med can provide data preparation, reconciliation and back-office coordination within agreed controls. Employers remain responsible for lawful entitlements, data protection and the adequacy of their records.

The source material

  1. Keeping records: holiday entitlement ↗Acas · Accessed 4 November 2026
  2. Employment Rights Act 2025: annual leave records ↗UK legislation · Accessed 4 November 2026

Retrospective briefing · Published 4 November 2026. Historical figures and measures describe their period; consult current official guidance before acting. This article provides operational context. Legal, immigration, clinical and financial decisions need the responsible organisation’s qualified advisers.