Pay Register

A pay register records, for every employee and every wage period, what was earned, what was deducted and what was paid. It is the employer's own account of the wage relationship, maintained as it happens rather than reconstructed afterwards.

The obligation to keep one sits in the Code on Wages, 2019, in force since 21 November 2025, which requires every employer to maintain registers containing the prescribed particulars, in the prescribed form, and permits them to be kept electronically. The rules made under the Code set out what those particulars are. The other Codes carry parallel obligations for the records within their own subject matter.

The reason it exists is evidential. Wage claims are decided on records, and the party that has them is in a substantially better position than the party that does not. That asymmetry runs in the employer's favour when the register is complete and against it when it is not, because an employer required to maintain a record and unable to produce it has little to offer in response to the employee's version.

These three are constantly confused, including by systems that produce one and call it another.

They are also sequential. Attendance feeds the wage computation, the computation is recorded in the register, and the employee's share of the register is issued as the slip. An inconsistency between any two of them is the thing an inspection is looking for, because it means one of the three was produced independently of the others.

Beyond these, separate registers are prescribed under other legislation for particular subjects: fines and deductions, overtime, advances, leave, and the records required of contractors and principal employers. A single combined register is often permitted where it carries all the prescribed particulars, which is worth checking rather than assuming.

Three practical questions come up every time.

• What form? The prescribed one, set by the rules under the relevant Code, with the particulars listed there. A payroll report that happens to contain similar information is not automatically the register, and the gap is usually a couple of prescribed columns nobody noticed were missing.
• What medium? Electronic maintenance is permitted under the Codes, which is a meaningful change from the older regime's assumption of bound paper. It does not lower the standard: the record still has to be complete, contemporaneous and producible on demand.
• How long? For the prescribed period, which is long enough that records routinely outlive the payroll system that produced them. Verify the current retention requirement under each applicable Code and rule, since they are not uniform.

The retention point is where most organisations are quietly exposed. A payroll migration or a vendor change that leaves historical registers in a decommissioned system is a records failure that will not be noticed until someone asks for a period nobody can reach.

An inspector-cum-facilitator under the Codes typically works from the records outward, and the sequence is fairly predictable.

• Are the prescribed registers maintained at all, and do they carry the prescribed particulars?
• Do attendance, the wage register and the slips reconcile for a sample of employees and periods?
• Are deductions within the permitted categories and the overall ceiling, and where fines or damage recoveries appear, was the procedure followed and recorded?
• Do the wages paid meet the applicable minimum for the category of work, tested against the statutory definition of wages rather than gross pay?
• Do contractor employees appear where they should, and does the principal employer's record reflect what the contractor did?

The last point catches organisations that have complete records for their own employees and none for the people working alongside them under a contract. The principal employer's obligations do not disappear because a contractor was engaged, and the register is where that shows.

A register that exists but cannot be produced quickly is barely better than one that does not exist, because the moments when it is needed are the moments when time is short.

Three habits make the difference. Generate the register from the payroll run rather than assembling it separately, so it cannot drift from what was actually paid. Keep the prescribed particulars as fields rather than as free text, so a missing column is visible before an inspector finds it. And test retrievability for old periods occasionally, rather than discovering during an inspection that the last migration took the previous three years with it.

None of this is difficult where the payroll system treats statutory records as an output of the run. It is very difficult where the register is a report someone builds afterwards from a spreadsheet.