And speaking of en-title-ment (geddit?) brings me to the curiously papery case of Leedham v Royal Mail Group Ltd 2026, in which a digitally savvy employee objected to losing his printed payslips. Strongly enough to bring the matter to tribunal.

Mr Leedham worked as an operative post-grade employee. Until May 2023, Royal Mail provided itemised pay statements in paper form. In April 2023, however, it notified employees that, from June 2023, payslips would be issued exclusively in digital form and made available through a People App or via a web browser on other devices. Paper payslips would be retained only for employees with a disability or medical condition preventing digital access.

From June 2023, Mr Leedham did not receive paper payslips and did not access his payslips electronically, despite owning a smartphone capable of doing so. He also accepted that he could use free public facilities, including a local library, to view and print his payslips.

The Employment Tribunal found that Mr Leedham had no medical or other impediment to accessing the digital system and that the employer had made his itemised pay information continuously available electronically from June 2023, having clearly explained how it could be accessed. The ET therefore dismissed his claim, finding that the employer had complied with its obligations under section 8.

Section 8 provides that every worker has the right to be given a written, itemised pay statement at or before the time at which their wages or salary are paid. The ET found that the word “given” was not limited to physical delivery but encompassed making the information available in a readable, written form. It held that, where Mr Leedham has no medical or practical impediment to accessing a digital system and the employer provides reasonable means of accessing the information, the statutory purpose of section 8 is satisfied.

Mr Leedham appealed to the Employment Appeal Tribunal, arguing that providing access to electronic-only payslips did not satisfy the requirement to “give” a payslip. He submitted that the ordinary and natural meaning of “given” required the actual provision or delivery of the payslip by the employer, rather than merely facilitating access to it. On that basis, he argued that the ET had erred in law by equating “given” with “made available” or “accessible”.

The EAT dismissed the appeal and upheld the ET’s decision.

The EAT held that the purpose of section 8 is to promote transparency in pay by enabling workers to understand, in an intelligible and reasonably accessible form, how their remuneration has been calculated and whether any deductions have been made. The question is therefore not whether the payslip has been physically handed to the worker, but whether the employer has provided the relevant information in a way that enables the worker to fulfil that purpose. Accordingly, the statutory obligation under section 8 may be satisfied by electronic means.

The EAT emphasised, however, that the question is fact-sensitive. Although section 8 does not entitle a worker to insist on a particular method of delivery, the method adopted must allow the worker to access their payslip in practice. An electronic system may therefore be insufficient where it imposes significant costs or other material barriers, or where an employee has a specific difficulty preventing access.

In Mr Leedham’s case, the system was free to use, and he had the means to access his payslips but did not do so. The EAT therefore concluded that the employer’s system satisfied the statutory purpose of section 8 and dismissed the appeal.

The decision in in this case provides useful guidance for employers and HR professionals considering the use of digital payslips. It confirms that section 8 of the Employment Rights Act 1996 does not require payslips to be provided in physical form and that electronic provision can satisfy the statutory requirement, provided workers can access the information in practice.

The decision also highlights the importance of considering accessibility when implementing digital systems. Employers should ensure that workers are given clear instructions on how to access their payslips and that reasonable alternative arrangements are available where a worker is unable to use the digital system due to a disability or other practical barrier. While workers cannot insist on a particular method of delivery, employers should ensure that their chosen method does not, in practice, prevent workers from exercising their statutory right to receive an itemised pay statement.

This case therefore provides reassurance that moving to electronic-only payslips can be lawful, while emphasising the need for a practical and accessible system that enables workers to obtain and understand their pay information.