New Holiday Record Rules: What Employers Need to Know
A change under the Employment Rights Act 2025 means employers now have a specific legal duty to keep adequate records showing that they are complying with statutory annual leave and holiday requirements.
The requirement came into force on 6 April 2026 and the records must be kept for at least six years from the date they are made.
What has changed?
For most employers, the amount of statutory holiday has not changed. What has changed is the requirement to be able to demonstrate that you are managing it correctly.
There is no prescribed system employers have to use. However, businesses should have clear and accessible records of employees' holiday entitlement and the leave they have taken.
This is particularly worth reviewing if holiday information is currently spread across spreadsheets, emails, paper forms or individual managers.
Failure to keep adequate records is an offence and can result in a fine.
Where RfM Transform can help
This is exactly the kind of change that catches smaller businesses off guard, particularly when there was no clear government announcement and it does not appear on the official ERA timeline. Employment lawyers only spotted it in the legislation days before it took effect.
RfM Transform provides director-led HR support for businesses of all sizes, on a retained basis with no contract lock-in. That means when changes like this come in, you have a specialist on hand to make sure you understand what is required and that your processes are in order, without needing a full-time HR resource to do it.
Whether it is reviewing how your leave records are currently managed, updating your policies, or simply getting clarity on what the new rules mean for your business, that is the kind of practical, day-to-day support our HR packages are built around.
The new rules do not mean every employer needs an HR department. They do mean that having access to the right advice, at the right time, is becoming more important. If you are unsure whether your current records are good enough, get in touch and we can talk it through.