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Electronic payslips capable of meeting statutory requirements

The Employment Appeal Tribunal has confirmed that the provision of electronic payslips is capable of meeting statutory requirements. In Leedham v Royal Mail Group the claimant’s appeal was dismissed, with the EAT holding “that the requirement in section 8 Employment Rights Act 1996 to be “given” an itemised payslip does not require physical delivery and can be satisfied by electronic provision”. 

The claimant, Mr G Leedham, was employed by the Royal Mail Group. Prior to 2023, paper payslips were provided. In April 2023 the respondent notified staff that from June 2023 payslips would be provided exclusively in digital form “accessible via the People App or through a web browser on other devices and that paper payslips would be retained only for employees with a disability or medical condition preventing digital access”. The claimant acknowledged he had access to a smart phone and could access a local library to print them, and had no medical or other impediment to accessing a digital system.

The EAT found that the purpose of s.8 is to ensure transparency of pay and enable employees to understand and challenge deductions. Electronic payslips are therefore compliant in principle where the information is provided in an accessible, intelligible form, and the focus is on substance rather than the method of delivery. The EAT emphasised that “compliance is fact-sensitive and a system may fail if it imposes real barriers or burdens on employees, while noting that privacy concerns could arise in other cases but were not properly before the Tribunal here”

For further information or to discuss how this may affect your business, please contact Jessica Jones or Kim Knox at Ortolan Legal Ltd.

Posted on 06/23/2026 by Ortolan

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