News

Employers are facing a new kind of summer pressure.

For years, managing annual leave, school holidays and major sporting events was seen as the primary seasonal challenge for HR teams and business leaders.

Today, however, summer is becoming a far broader compliance test.

Alongside workforce absences, employers are having to navigate increasingly frequent heatwaves, heightened employee wellbeing expectations and new holiday record-keeping obligations. While these issues may appear unrelated, they point to a significant shift in employment law and workplace regulation.

The modern employer is no longer judged solely on having appropriate policies.

Increasingly, employers are expected to demonstrate those policies are being followed, monitored and evidenced in practice.

Why Workplace Heat Is No Longer an Exceptional Event

Recent years have fundamentally changed how employers should view extreme weather.

Heatwaves can no longer be dismissed as rare disruptions. The Met Office has repeatedly warned that periods of extreme heat are becoming more likely as climate patterns continue to change, increasing the likelihood that businesses will need formal processes for managing high-temperature working conditions.

For employers, this means workplace heat should increasingly be treated as a foreseeable operational risk rather than an occasional inconvenience.

The legal position in the UK remains an interesting one.

While there is a minimum workplace temperature requirement of 16°C (or 13°C for physically demanding work), there is currently no legal maximum workplace temperature.

However, that does not remove employer obligations.

Health and safety legislation requires organisations to provide a safe working environment and undertake appropriate risk assessments. During periods of exceptional heat, employers should be able to demonstrate they have considered potential risks and implemented reasonable measures where necessary.

As a result, the question is no longer:

"Is there a maximum workplace temperature?"

Instead, employers should be asking:

"Can we show we took reasonable steps to protect our employees?"

Declining Office Attendance Highlights Changing Employee Expectations

Recent heatwaves have also revealed another workplace shift.

Research tracking workplace attendance found significant drops in office occupancy during periods of extreme heat, suggesting many employees opted to work remotely rather than contend with uncomfortable workplaces or disrupted transport networks.

Whether organisations operate hybrid, office-based or frontline workforces, employee expectations around wellbeing continue to evolve.

Workers increasingly expect employers to take a proactive approach to environmental conditions, workplace comfort and health risks.

Businesses that fail to adapt may face more than reduced productivity. They may also face employee relations challenges, increased grievances and greater difficulty attracting and retaining talent.

What Should Employers Do During a Heatwave?

There is no one-size-fits-all solution.

The appropriate response will depend on the nature of the workplace, the work being undertaken and the needs of individual employees.

An air-conditioned office presents very different challenges to a warehouse, manufacturing facility, construction site or outdoor working environment.

Practical measures may include:

• Providing easy access to drinking water
• Allowing additional rest breaks
• Improving ventilation and airflow
• Introducing temporary dress code flexibility
• Adjusting work schedules to avoid peak temperatures
• Providing cooling equipment where appropriate
• Reviewing hybrid or flexible working arrangements

Employers should also pay particular attention to vulnerable groups, including:

• Pregnant employees
• Workers with disabilities
• Employees with health conditions affected by heat
• Older members of the workforce

Crucially, any actions taken should be documented.

That evidence may become just as important as the measures themselves.

Holiday Record-Keeping Has Entered a New Era

The same principle now applies to annual leave.

Since 6 April, employers have been required to maintain records demonstrating compliance with holiday entitlement and holiday pay obligations.

For many organisations, this represents a significant cultural shift.

Historically, it was often enough to show that systems were broadly compliant and operating correctly. Increasingly, businesses must now maintain records capable of evidencing exactly how annual leave and holiday pay have been calculated.

The requirements apply across the workforce, including:

• Part-time employees
• Casual workers
• Zero-hours staff
• Workers with irregular hours

Records must be retained for six years and be available if requested.

The Growing Risk Around Holiday Pay

Holiday pay remains one of the most litigated areas of employment law.

Complex working arrangements, variable earnings, overtime payments and commission structures can all create challenges when calculating entitlement correctly.

Under the current framework, employers may need to demonstrate:

• Holiday entitlement calculations
• Holiday taken
• Holiday pay calculations
• Payments in lieu of leave
• Holiday carry-over arrangements

Businesses that cannot evidence compliance could face significant legal and financial consequences.

This makes integrated HR and payroll systems more important than ever.

The Emergence of the "Evidence Employer"

A common thread runs through both workplace heat management and holiday compliance.

The most important question employers increasingly need to answer is:

"Can we prove it?"

Can you prove you assessed workplace risks?

Can you prove employees were able to take their leave?

Can you prove holiday pay was calculated correctly?

Can you prove reasonable adjustments were considered for vulnerable workers?

This growing emphasis on evidence is reshaping employer compliance obligations across the board.

Policies alone are no longer sufficient.

Documentation, audit trails and demonstrable decision-making are becoming equally important.

Key Takeaways for Employers

As summer pressures continue to build, organisations should take the opportunity to review both operational and compliance processes.

Priority actions include:

Heatwave Preparedness

• Review workplace risk assessments
• Update heat-related wellbeing procedures
• Ensure managers understand escalation processes
• Consider vulnerable employees and reasonable adjustments
• Document action taken during periods of extreme heat

Holiday Compliance

• Audit holiday pay calculations
• Review leave entitlement processes
• Check HR and payroll systems are aligned
• Maintain auditable records
• Ensure documentation can be accessed if required

Conclusion

The real challenge facing employers this summer is not simply staffing holidays or coping with high temperatures.

It is adapting to a workplace environment where evidence increasingly matters as much as action.

Whether dealing with heatwaves, annual leave or wider workforce management issues, employers are entering an era where compliance must be visible, measurable and documented.

In other words, businesses are facing their own version of a heat dome.

The best form of cooling remains the same as ever:

Preparation before the pressure arrives.