Does an employer need to provide a physical itemised payslip to workers?
Section 8 of the Employment Rights Act 1996 states that a worker “has the right to be given by his employer, at or before the time at which any payment of wages or salary is made to him, a written itemised pay statement.”
Whether the word “given” means that employers must provide a physical payslip, unless the employee agrees otherwise, was considered by the Employment Appeal Tribunal (EAT) in Leedham v Royal Mail Group [2026]. Royal Mail had moved from paper-based payslips to a digital-only system, with payslips accessible via a smartphone app or web browser.
Mr Leedham (L), a postal operative, objected to the change despite having access to a smartphone and the option of using a local library to access his payslips free of charge. He chose not to use either option.
L brought a claim against Royal Mail, arguing that, under Section 8 of the Employment Rights Act 1996, the employer had failed to “give” him an itemised pay statement.
The Employment Appeal Tribunal considered the earlier case of Ridge v HM Land Registry UKEAT/0098/10, which established that the purpose of an itemised pay statement is to enable workers to see clearly how their pay has been calculated and to identify any deductions. The EAT rejected L’s interpretation of the word “given”, concluding that it does not require physical delivery of a payslip.
The EAT held that Section 8 is intended to provide workers with transparent information about their pay so that they can challenge any discrepancies or deductions. This purpose can be achieved through electronic delivery, provided the information is genuinely accessible to the worker. The tribunal therefore adopted a purposive interpretation of the legislation rather than a strictly literal one.
On the facts of the case, Royal Mail’s digital system did not create any significant barriers for L. There were no technical constraints, cost implications, or other practical difficulties preventing him from accessing his payslips. He had the means to do so and was not subject to any coercion or disadvantage.
The decision confirms that electronic payslips can satisfy the requirements of Section 8 of the Employment Rights Act 1996, provided the information is readily accessible, easy to understand, and available to the worker. The focus is on the substance of providing the information rather than the method of delivery.
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