What Payslips Look Like Around the World
Aug 29, 2019 | Topic: Country Payroll
Probably the most eagerly awaited document in any company, the payslip can be a herald of good tidings like a pay increase, a required income certificate that unlocks other goodies such as government benefits or access to credit, or simply a comforting reminder that the employer has upheld their side of the employment agreement. It is the one piece of corporate communication that every employee receives regularly and whose absence will generally be noticed – and queried.
In general, the legal requirement to provide a payslip is included either in the basic labor law of a country or specific legislation written on the payment of wages. To meet these requirements, global payroll teams rely on local employment law to dictate the contents of the document, the timing of its delivery, the layout, and even the font size to be used, and these requirements can vary significantly from country to country. Here, we take a look at some of the country-specific laws for payslips, as well as payslip delivery and use around the world.
One example of specific legislation on the payment of wages is the law in the Republic of Ireland, The Payment of Wages Act 1991, which sets three broad requirements: that employees will receive a negotiable mode of wage payment (in other words, they are paid in currency rather than goods or tokens), that a written statement of wages paid and deductions taken is given to the employee, and that the employer may not take unlawful deductions from the employee’s wages.
The Act is remarkably short on detail in determining what should appear on the payslip, stating simply: “An employer shall give or cause to be given to an employee a statement in writing specifying clearly the gross amount of the wages payable to the employee and the nature and amount of any deduction there from.”
So the law envisages a very simple document that does not even require the employer’s name or a breakdown of gross pay. The timing of the delivery of the document is also left vague: If the employee is paid in cash, the payslip must be given at the time of payment, but if bank credit transfer is used, the law simply states that delivery should be made “as soon as may be thereafter.” So it appears that a delay of a few days could be acceptable under the law.
The law concerning the payslip (or Lønseddel) in Denmark requires a more detailed document, although payroll best practice would ensure that a somewhat more comprehensive document was issued to an employee. The law specifies that a written payslip must contain five sections of data:
- The amount of employee's earnings during the period
- The applicable period for the payslip
- Amounts deducted, for ATP pension contribution, A tax and AM contributions, and any other deduction authorised by the employee
- Employee's name, address, and CPR number
- Employer's name, address, and relevant CVR number
The law also requires the employer to retain payslip data for a minimum period of five years.
Singapore only recently introduced the legal requirement to provide a written statement of pay with the Employment Act 2016. The law requires the payslip to be provided at the time of payment or, if this is not possible, within three working days of the payday. For leavers, the payslip must be provided with the residual salary payment. As far as the required content, the Singapore payslip is a comprehensive document that reflects accepted payroll best practice. The content mandated by law are:
- Name of employee and employer
- Date and period of payment
- Basic salary
- Full breakdown of other elements of pay
- Overtime hours worked and cash paid
- Period the overtime covers, if different from the standard wages period
- All deductions on an itemized basis
- Net pay
Clearly this requires a lot more effort to produce than those required by Irish or Danish law. In particular, the requirement to include details of working time for overtime pay will require more information to be provided to the payroll. Payslip information must be retained for two years or, in the case of a leaver, one year after termination of employment. Standard accounting practice would dictate that this information be retained for a much longer period, so companies are unlikely to inadvertently fall foul of the retention requirements.
To assist employers in designing compliant payslips, the Ministry of Manpower in Singapore issues a payslip template that employers can use as a design starting point, which can be downloaded from their website.
In South Africa, the Basic Conditions of Employment Act s33 sets the requirement that all employers provide a payslip. The document must be provided at the workplace or another place agreed in advance with the employee. Payslips must be provided on the day that the employees are paid, either during employees’ ordinary working hours or within 15 minutes of the start or finishing time. The Act mandates that all payslips include:
- Employer’s name and address
- Worker’s name and occupation
- Period for which payment is made
- Total salary or wages
- Any deductions, such as for national insurance or income tax
- Actual amount paid
- If relevant to the calculation of pay, the worker’s pay and overtime rates, the number of ordinary and overtime hours worked, and the number of hours worked on a Sunday or public holiday
France has a justified reputation for challenging and complex payroll legislation, and the provision of payslips is no exception. The basic labor law mandates a large number of data items to be included on the payslip, with more than twenty data fields specified on the current version. As a result, the layout of a French payslip is very standardized between employers and payroll providers, and there is little scope for customization.
Adding to the complexity, the law specifying payslip content changes regularly. The most recent changes were effective from May 13, 2018, then October 1, 2018, and then from January 1, 2019, just to give an idea of how frequently changes might be made. The law also actively prevents the employer from mentioning the right to strike or the functions of a staff representative on the document. The wording must contain a reminder that the Service-Public website has a section dedicated to the payslip contents as well as a reminder to the employee to retain a copy of their payslip forever (yes!) as it is needed as a document to complete tax returns. By law, the employer must retain payslip data for five years.
A French payslip is a busy document containing lots of information. One area that non-French businesses struggle with getting right in France is the requirement to report and record all forms of working time and absence via the payslip. It is very important that a payroll provider is fed accurate data regarding the taking of holiday, sick, and parental and family leave, as all of these events need to be recorded on the payslip.
In addition, any business which works in excess of a 35-hour week must record on the payslip any reduction du temp du travail (RTT) days accrued and taken, as well as any forfait annuel entitlement to additional days off awarded to senior managers who are not required to track their working time on a weekly basis.
The Importance of Proper Payslips
Regardless of country specifics, most jurisdictions mandate the issue of a payslip, and failure to provide one will be a breach of labor law. It’s an area that labor inspectors across the globe will check, and the penalties issued for non-compliance can be significant. Here is a summary of the penalties issued in some of the countries mentioned:
|Ireland||€1,500 for each missed payslip|
|Singapore||SGD 100 - 200 per omission|
|South Africa||ZAR 300 - 1,500 per employee|
|France||Class 3 fine of up to €450 plus appropriate damages awarded to the employee|
When it comes to variations in required payslip content, everything from the personal information included to net versus total amounts to whether deductions are itemized is different from country to country. Determining the mandatory payslip requirements for each jurisdiction in which you are responsible for payroll is important. Get it wrong and the financial consequences (never mind the impact on employee morale) can be significant.