Many employers have moved payroll online. It saves time, cuts costs and suits most employees. But does making payslips available through an app or web portal meet your legal duty to provide an itemised payslip?

The Employment Appeal Tribunal (EAT) has now answered that question.

What happened?

Royal Mail replaced paper payslips with digital versions that employees could access through its People App or a web browser. Paper payslips remained available only for employees whose disability or medical condition prevented digital access.

Mr Leedham challenged the change. He argued that section 8 of the Employment Rights Act 1996 requires an employer to ‘give’ an itemised payslip and that making one available online was not enough.

Although he acknowledged that he owned a smartphone and could access the internet elsewhere without charge, he chose not to do so.

What did the EAT decide?

His Honour Judge Beard held that an employer could satisfy its obligation under section 8 by providing payslips electronically. The legislation does not require a paper document or physical delivery. What matters is whether the employee can genuinely access the information.

Why did it reach that decision?

The Tribunal adopted a practical, purposive approach.

The purpose of section 8 is to ensure workers understand how their pay has been calculated and can identify and challenge any deductions. That objective can be achieved through digital delivery just as effectively as through paper, provided the information is accessible, intelligible and available when required.

The judgment is not, however, a blank cheque for digital-only systems.

The EAT stressed that compliance depends on the facts. An employer may still fall short when employees face genuine barriers, such as high costs, technical obstacles, or other practical difficulties.

Different facts could produce a different outcome.

What should you do now?

• Check that every employee can access digital payslips without unreasonable cost or difficulty.
• Build sensible exceptions into your process for employees with disabilities, medical conditions or genuine digital exclusion.
• Keep your medical and disability exemptions current, and make sure staff know they exist.
• Keep evidence of how employees are told where and when payslips are available.
• Review payroll systems through a governance lens. Convenience for the business should never create hidden barriers for employees.
• If you mandate an app, ask what it tracks. Data pulled from personal phones could be your next exposure.

Source: Mr G Leedham v Royal Mail Group Ltd: [2026] EAT 87 – GOV.UK