The leave register is a direct obligation under Article 95 of the Labor Code. For each employee, the start date of employment, the length of the leave to which they are entitled, the dates on which the leave was taken, and the pay granted for annual leave must be recorded. This register is presented whenever requested by labor inspectors and by the tax administration.
This page shows what the leave register contains, how it's actually maintained, which deadlines are followed, and what a business risks when it's missing.
Read also: Schedule, breaks and leaves: the complete guide
Article 95 establishes two separate obligations that are often mistaken for a single one.
Employers are required to maintain up-to-date payroll and contribution payment records for all employees working for them and to present these records whenever requested by labor inspectors and authorized tax administration inspectors.
Employers must keep a record, in accordance with the rules set forth in this law, noting for each employee the date employment began, the length of the leave to which they are entitled, the dates on which the leave was taken, and the pay provided for paid annual leave.
The first paragraph deals with salaries and contributions, with a monthly update. The second paragraph deals with leave and does not specify a frequency, because it is updated whenever an event occurs, that is, when a day off is granted or taken.
| Column | Content | Why is it required? |
|---|---|---|
| Start date of employment | First day of employment | From that, the break is calculated relative to the time worked. |
| The duration that applies | Vacation days for the coming year | No fewer than 22 working days, pursuant to Article 92. |
| Date of receipt | The exact days when the break took place. | They prove that the break was actually granted. |
| Given salary | The amount paid for vacation days | Try applying Article 94. |
Read also: Annual leave: 22 working days per year
The register is not just a list. It serves to prove that the deadlines of Article 93 have been met.
| Deadline | Rule | Article |
|---|---|---|
| Advance notice | The employee is notified of the start date of the leave at least 30 days in advance. | 93/1 |
| Postponement due to illness | Leave is postponed when the employee is hospitalized or falls ill, with a medical certificate. | 93/2 |
| Expiration date | Vacations are granted within the year or by the end of the first quarter of the following year. | 93/3 |
| Prescription | The right to unused leave expires after three years. | 93/4 |
| Payment | Vacation pay is provided at the time the vacation is taken. | 94/4 |
Without a register, you can't prove 30 days' prior notice, and you can't meet the first-quarter deadline. Both are among the most frequently checked items.
Article 94, paragraph 5, prohibits replacing vacation with cash, with only one exception. When the employment relationship ends and the employee has not taken the leave to which they are entitled, they receive a payment equal to the pay for that leave. This calculation is made directly from the leave record, so any inaccuracies become apparent on the day of departure.
Read also: The step-by-step termination of the employment relationship
The code explicitly requires annual leave, but in practice the same record also tracks the other days that affect pay and schedule.
When these are kept on separate sheets, the link between them is lost and the year-end calculation comes out wrong.
Read also: Special permits and paid days
This template has been prepared by AlProfit Consult based on Article 95. You can copy it into an Excel spreadsheet or print it as a separate sheet for each employee.
Annual Leave and Leave Register
Subject: company name, NUIS
Calendar year: the corresponding year
Prepared by: name and function
Last update date: date
Section A. Employee's Basic Information
Full Name
Job position
Start date of employment
The vacation days to which you are entitled for the year
Carryover days from the previous year
Total available
Section B. Days taken during the year
Serial number
Type: annual leave, substitute leave, special leave, unpaid leave
Date of preliminary notice
Start date
Expiration date
Number of days
The pay given for these days
Employee's signature
Section C. Closing Statement
Total days taken
Days remaining
Expiration date: March 31 of the following year.
Signatures of the employer and the employee
The signature column is not required by law, but it is the simplest proof that the break was actually granted and taken.
Read also: Ready-made templates and forms for employment
The register contains personal data, and therefore also falls under Law No. 124/2024 on the protection of personal data. The legal basis here is legal obligation and contract, not the employee's consent.
In practice, this means three things. The register contains only the data required by Article 95 and nothing more. Access is granted only to those who need it for their work. The medical reason for a postponement is not recorded in the register; a reference to the medical report, which is kept separately in the file, is sufficient.
Read also: Employee file and mandatory records
Article 95 is part of the group of Articles 91 to 96 mentioned in Article 202, paragraph 2. For these violations, the fine goes up to thirty times the monthly minimum wage.
With the current minimum wage of 50,000 LEK, this means up to 1,500,000 LEK. The fine is expressed as a multiple, so it automatically increases whenever the minimum wage goes up. Minimum wage. When the violation affects several employees, the total does not exceed five times the maximum fine.
Read also: Documents required for a workplace inspection
Yes. Article 95, second paragraph, of the Labor Code explicitly requires it for every employee.
Start date of employment, the length of leave to which the employee is entitled, the dates on which the leave was taken, and the pay granted for it.
The law does not prescribe any format. It may be kept on paper or in electronic form, provided it is complete, up to date, and available whenever requested.
Labor inspectors and authorized inspectors of the tax administration, pursuant to Article 95, first paragraph.
Within the fiscal year or by the end of the first quarter of the following year, in accordance with Article 93, paragraph 3.
They are paid as compensation equal to the pay for those leave days, in accordance with Article 94, paragraph 5.
Three years from the date on which employees acquire this right, in accordance with Article 93, paragraph 4.
Yes. Article 202, paragraph 2, provides for a fine of up to 30 times the monthly minimum wage.
Read also: Proper reporting of employees and wages
