Employment law
Which registers must an employer keep, and for how long? Five years at least, and not only for payroll
Month end at Clinique Djoliba. The accountant prints the payslips, hands them out, then files the copies in a cardboard box. The register? “It’s all on the computer.” The day the labour inspector asks for the numbered and initialled employer’s register, the box is no longer enough: every missing entry has a price, and a three-year-old pay dispute is lost for lack of proof.
1. What exactly are we talking about?
Clinique Djoliba is a fictitious company: a private clinic with 60 employees in Bamako, 8 of whom work at an annex 12 km away. Its name and situation are used purely as an example.
A compulsory register is a document the law requires the employer to keep up to date and produce to the labour inspector. It proves what the company has done: whom it employs, what it has paid, what the inspector has asked of it.
Two registers form the foundation: the payments register and the employer’s register. Others are added depending on the activity: machine safety, fire drills, lifting equipment, the health and safety committee, staff delegates.
Why this requirement? Because the register is evidence. In a pay dispute, the employer must show that it paid, and the employee has three years to claim wages, bonuses and allowances (Labour Code, article L.118).
“A well-kept register is the employer’s best defence.”
2. The payments register: a copy of every payslip
At each payment, the employer gives the employee an individual payslip, whose particulars are reproduced in the payments register (Labour Code, article L.104). This register also contains a record of absences, broken down by cause: sickness, workplace accident, authorised or unauthorised absence (Labour Code, article L.107).
The form that gives it its value
The paper register is a set of fixed, continuously numbered sheets, bound in board covers. It is kept in date order, without blanks, gaps or overwriting; any crossing-out must be approved by the worker (Labour Code, article L.108).
It may be replaced by a computerised file or listing on two conditions: the medium gives all the particulars with no risk of alteration, and the computerised register is validated by the competent authority, INSTAT (article L.107).
Order No. 96-1566 of 7 October 1996 allows some flexibility. A counterfoil book with numbered sheets, whose first and last pages are initialled, counts as a register (article A.109-10). In a company with several establishments, the register is kept at each establishment, unless the inspector agrees to a single register for one town or region (article A.109.8).
There are only two exemptions. An employer of domestic staff keeps no payments register, but issues a payslip (article A.109-12) and keeps the signed duplicates for five years (Decree No. 96-178/P-RM of 13 June 1996, article D.86-15). An agricultural business with fewer than ten workers may obtain a written, temporary and revocable exemption from the inspector (article A.109.11).
The most common mistake
Keeping payslips loose, or in a spreadsheet anyone can edit. A file that can be changed without trace does not replace the register: the medium must rule out any risk of alteration and be validated.
What you need to do
- Reproduce every payslip in the register, in date order.
- Record absences and their cause at every payroll.
- Have any computerised register validated before giving up paper.
3. The employer’s register: three sections and an official stamp
The employer’s register is kept constantly up to date, under the same conditions as the payments register (Labour Code, article L.130). Its content is set by Order No. 2024-4363 of 27 December 2024 (article A.130.1).
| Section | What it contains |
|---|---|
| First | People and contracts: serial number, start date, surname and firstname, date of birth, identity card or NINA biometric card number (withplace and country of issue), nationality, INPS registration number,leaving date |
| Second | Work, pay and leave: job, occupational category, basic salary,salary supplements, paid-leave dates, work permit number for foreignworkers |
| Third | The inspector’s approvals, observations and formal notices: date,subject, deadline set, signature, follow-up |
Before any use, the register is numbered and initialled by the local labour inspector: its pages are numbered and stamped. It is kept at the place of operation and filled in without overwriting, and without missing or incorrect entries (articles A.130.1 and A.130.2). For a foreign employee’s file, see Hiring a foreign national: work permit, file, deadlines, fees.
Each establishment keeps its own register. Exception: establishments with fewer than ten workers located within a 20 km radius may keep a single register, stating for each employee, in the second section, the establishment where they work (article A.130.3). Clinique Djoliba’s annex, 8 employees 12 km away, falls within this case; the safest course is to have the chosen arrangement approved by the inspector when the register is stamped.
Individual record cards initialled by each employee may replace the second section. A computerised file may replace the register if it contains all the particulars; the employer then keeps a separate register for the inspector’s observations and formal notices (article L.130).
What a badly kept register costs
Breach of article L.130 is punishable by a fine of 20,000 to 50,000 XOF and 15 days to 3 months’ imprisonment, or one of these penalties, and the fine applies as many times as there are missing or incorrect entries (Labour Code, article L.319). On the spot, the inspector may collect a fixed fine of 18,000 XOF per missing or incorrect entry (Order No. 2024-4363, article 2).
Example. Clinique Djoliba, employer’s register never opened for its 60 employees:
Fixed fine on the spot: 60 × 18,000 = 1,080,000 XOF Before the court, gross calculation: 60 × 50,000 = 3,000,000 XOF Article L.335 ceiling: 50 × 50,000 = 2,500,000 XOF A register opened on time would have avoided all this risk.
What you need to do
- Have the register numbered and initialled by the inspector before the first entry.
- Enter each employee on hiring, with their INPS number and, for a foreign worker, their permit number.
- Keep one register per establishment, except for small nearby sites approved by the inspector.
4. Other registers, depending on your activity
Decree No. 96-178 and Order No. 96-1566 add registers relating to safety and social dialogue. All are kept available to the inspector.
| Register | Who is concerned | What is recorded |
|---|---|---|
| Safety register (D.170-35) | Any company where a defective machine could cause an accident | Results of inspection visits, at least once a quarter |
| Lifting equipment register (D.170-33) | Companies with lifts or goods hoists | Maintenance, checks of cables and chains every six months, of safetydevices once a year |
| Fire drill register (D.170-26) | Establishments normally bringing together more than 50 people, orhandling highly flammable materials | Date and observations of drills and tests, at least every threemonths |
| Health and safety committee register (D.282-5) | Establishments required to have a committee | Minutes of meetings, results of post-accident investigations |
| Special staff delegates’ register (A.275.3) | Establishments with more than ten workers | Delegates’ written notes and the employer’s reply within sixdays |
The delegates’ register is open to employees one working day per fortnight, outside working hours, and permanently to the inspector (article A.275.3). On the health and safety committee, see Health and safety committee: from what headcount, and how to run it?
Other documents are kept without being registers: the pre-employment medical examination form, to be shown to the inspector (Social Security Code, article 43), the fourth copy of each workplace accident report (article 71), the third copy of the minutes of the staff delegate election (article L.268) and, for each young worker, the duplicate of their work card and a birth certificate extract (Decree No. 96-178, article D.189-34).
The most common mistake
Believing these registers only concern large factories. The safety register covers any machine whose defect could cause an accident, whatever the size of the company.
What you need to do
- List, site by site, the registers that apply.
- Appoint one person responsible per register, with an update date.
- File in one place the documents to be produced: medical forms, accident reports, minutes.
5. How long must they be kept?
The Code sets a period for the two main registers: five years after the last entry, for the payments register as for the employer’s register and the individual record cards replacing it (articles L.108 and L.130). A computerised medium is kept for the same period as the register it replaces (article L.107).
| Document | Retention period | Text |
|---|---|---|
| Payments register or computerised medium | 5 years after the last entry | L.107, L.108 |
| Employer’s register, individual record cards | 5 years after the last entry | L.130 |
| Duplicate payslips of domestic staff | 5 years | D.86-15 |
| Other registers | Not set: 5 years as a precaution | None |
Watch the starting point: it is the last entry made in the register, not the date it was opened. A register opened in 2015 and still in use in 2026 must be kept at least until 2031. For registers with no set period, keeping them five years comfortably covers the three years an employee has to claim wages.
The most common mistake
Destroying the pages of an employee who left a year ago. The period does not run employee by employee: it starts from the last entry made in the register.
What you need to do
- Archive each closed register with the date of its last entry.
- Destroy nothing until five years after that date.
- Back up computerised registers on a non-editable medium.
A closer look: templates imported from elsewhere
Many templates circulate under the names “single staff register” (registre unique du personnel) or “single risk assessment document” (document unique d’évaluation des risques). These are obligations under French law. In Mali, the staff register is called the employer’s register: it has three sections and must be numbered and initialled by the inspector before use. An imported template risks leaving out the third section, for the inspector’s formal notices, and Malian particulars such as the NINA number or the INPS number.
On payroll and supporting documents, see Payroll in Mali: paying on time, in the right place, and keeping the proof. On the fines incurred, see What fines does an employer face for breaching the Labour Code?
Key takeaways in 6 points
- Reproduce every payslip in the payments register, with absences and their cause.
- Have the employer’s register numbered and initialled by the inspector before the first entry.
- Keep all three sections up to date, including the inspector’s observations.
- Open safety, fire, committee and delegates’ registers where the activity requires them.
- Keep registers and computerised media for five years after the last entry.
- Have any computerised register validated and protect it against any alteration.