TemporAuto-enrolment: the records you have to keep, and for how long
Payroll runs, the pension contributions go out, everyone gets paid. That feels like the duty discharged. It isn't. Sitting behind it is a separate legal obligation to keep evidence of what you worked out and when, for six years, and the first time most employers think about it is the morning a letter from The Pensions Regulator lands asking to see it.
The records duty is small, dull and precisely written. Worth twenty minutes.
Where the duty comes from
Not the Pensions Act itself. The detail lives in the Employers' Duties (Registration and Compliance) Regulations 2010, SI 2010/5. Regulation 5 creates the requirement to keep records at all, regulation 6 lists what an employer has to keep, and regulation 8 sets how long.
Six years is the default. One category gets four: opt-out notices, which fall under regulation 6(1)(i). Both periods run from the day the record first had to be kept, not from the day somebody left or the scheme closed.
That distinction trips people up. Take an employee who joined in 2021 and opted out a fortnight later. The opt-out notice can go in 2025. Their name, National Insurance number, date of birth and enrolment date are ordinary regulation 6 records, so they stay until 2027, exactly as they would for a colleague who never opted out. Resigning in 2023 moves neither date.
What you actually have to hold
The Regulator splits it into records about your people and records about the scheme.
For each worker: name, National Insurance number and date of birth. The date they were automatically enrolled or opted in. Gross qualifying earnings in every relevant pay reference period. The contributions payable in each period, and the date each one was actually paid to the scheme. Any opt-in notice, kept in its original format.
For the scheme: the employer pension scheme reference, the scheme name and address. Defined benefit schemes carry extra items, which is a smaller problem than it used to be and not one most small employers have.
Read the earnings line again, because it is the one that quietly depends on your timesheets. Not annual salary. Gross qualifying earnings in each relevant pay reference period, which for anyone paid by the hour is a number that only exists because somebody recorded the hours.
The threshold nobody re-checks
In its review published on 18 December 2025, the Department for Work and Pensions held all three figures where they were for 2026/27. The earnings trigger stays at £10,000. The qualifying earnings band stays at £6,240 at the bottom and £50,270 at the top. Contributions are calculated on the slice between those two numbers, not on the whole wage.
Stability in the headline figures hides the awkward part, which is that assessment happens every pay reference period rather than once a year. A groundworker on variable hours can sit below the monthly equivalent of the trigger in March, work three Saturdays in April and land above it. At that point they become an eligible jobholder and you have a duty that starts on a specific date.
Get the hours wrong and you do not just underpay somebody. You miss an enrolment date, which means backdated contributions, employer and employee both, and a record of a decision you cannot evidence.
Postponement, and the paperwork it creates
Postponement is legitimate and widely used. You can delay assessing a worker by up to three months, which is genuinely useful for short-term staff who will have left before the deferral date arrives.
It is not a way of avoiding the duty and it is not silent. The written postponement notice has to reach the worker no later than six weeks and a day from the date you are postponing from, and if it misses that window you cannot postpone at all. The notice itself becomes part of the record. On the deferral date you assess the worker properly, on that day's earnings.
Employers who postpone everybody by habit usually end up with more paperwork than employers who don't.
Re-enrolment comes round again
Every three years you re-enrol eligible staff who previously opted out or left the scheme, choose a re-enrolment date, and complete a re-declaration of compliance. The re-declaration is a legal duty in its own right, separate from the enrolment itself, and missing it is one of the more common reasons a compliant employer ends up with a penalty notice.
Diary it. Three years is long enough that nobody remembers, and the Regulator writes to the address it has on file rather than the one you moved to.
What format, and who can hold it
Regulation 6 does not prescribe a system. Records have to be kept in a form that is legible, or that can be produced to the Regulator in a legible format. Your existing payroll output counts. A spreadsheet counts, if it is the real thing and not a summary somebody rebuilt afterwards.
Notices are the exception. Opt-in and opt-out notices should be kept in their original format, so a scan or an electronic copy of the actual notice rather than a payroll field reading "opted out 14/03".
You can hand storage to a third party. Your payroll bureau, your accountant, the pension provider. What you cannot hand over is the responsibility: if the Regulator asks, you are the one who has to produce it, and "our old bureau has it somewhere" is not an answer that ends the conversation.
What happens when you can't produce it
The sequence is set out in the same regulations and it escalates fast.
First a compliance notice, telling you what to fix and by when. Ignore it, or fail to satisfy it, and you get a fixed penalty notice. That one is £400 flat, whatever size you are.
Then it stops being flat. An escalating penalty notice sets a new deadline and, after that, charges a daily rate from Table 1 of regulation 13, scaled by how many people are in the PAYE scheme:
| Number of persons | Prescribed daily rate |
|---|---|
| 1 to 4 | £50 |
| 5 to 49 | £500 |
| 50 to 249 | £2,500 |
| 250 to 499 | £5,000 |
| 500 or more | £10,000 |
A firm with eleven people on the books accrues £500 a day, every day, until it complies. Three weeks of ignoring the post is £10,500 plus the original £400. Nobody plans for that; people just don't open the envelope.
Where records actually go wrong
The pension records themselves are rarely the failure. The pension provider holds contributions, payroll holds the payslips, and between them most of regulation 6 is covered by accident.
What is usually missing is the earnings figure per pay reference period for variable-hours staff, in a form you can stand behind three years later. Site workers, casual staff, anyone on a day rate that moves. The contribution figure exists because it was paid. The hours it was calculated from exist on a paper sheet in a van, or in somebody's phone, or nowhere.
That is the gap worth closing, and it is not really a pensions problem. It is a time-records problem that shows up in pensions, in minimum wage checks, and in holiday records, all at once.
Common questions
How long do I keep auto-enrolment records?
Six years, under regulation 8 of the Employers' Duties (Registration and Compliance) Regulations 2010. Opt-out notices are the exception at four years. Both run from the day the record first had to be kept.
Do I have to keep records for staff who opted out?
Yes. You keep the opt-out notice for four years, and the other records about that worker for six. Someone opting out is a decision you have to be able to evidence, not a reason the file disappears.
What is a pay reference period?
The period your pay is calculated for: a week for weekly paid staff, a month for monthly. Assessment against the earnings trigger happens for each one, which is why a worker's status can change from one payday to the next.
What are the auto-enrolment thresholds for 2026/27?
The earnings trigger is £10,000. Qualifying earnings run from £6,240 to £50,270, and contributions are worked out on the slice between those figures. All three were held at their previous levels in the review published on 18 December 2025.
Can my payroll bureau keep the records for me?
It can hold them, and most do. The duty to produce them to the Regulator stays with you as the employer, so it is worth knowing where they are and in what format before somebody asks.
What is the fine for not keeping records?
A fixed penalty notice is £400. If that does not get compliance, an escalating penalty notice charges a daily rate set by regulation 13, from £50 a day for an employer with up to four people to £10,000 a day for 500 or more.
Does postponement mean I keep fewer records?
No, it means one more. The postponement notice has to reach the worker within six weeks and a day and then be kept, and you still assess them properly on the deferral date using that day's earnings.
How does this relate to minimum wage record keeping?
They are separate duties with different tests, but they draw on the same underlying hours. National Minimum Wage records have their own six-year rule and their own HMRC check, which we covered separately.
Where hours fit in
Temporra records the hours people actually worked: clock-in and clock-out, against a job and a site, with a face check at the point of clocking in so a colleague cannot do it for somebody who is not there. It is a descriptor match against a stored photo, which stops buddy punching and is not a liveness test, so treat it as one control rather than proof of identity.
It does not run payroll, it does not assess anyone against the earnings trigger, and it does not build your rota. What it gives you is the number underneath all of those: gross hours per person, per period, exported and defensible, so the qualifying earnings figure you record has something real behind it.
Related guides
- How to Run Payroll for a Small Business (UK): A Practical 2026 Guide
- Maternity pay records: what you must keep, and for how long
- Payslips and hours worked: what the law actually requires
- The 12-Week Clock: What Equal Treatment for Agency Workers Actually Takes
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