Reactive (response to change)

Nearly 400 employers fined and named for minimum wage underpayment

HMRC has named 389 employers who collectively owed more than £7.3 million to around 60,000 workers for failing to pay the correct National Minimum Wage or National Living Wage. Fines totalling £12.6 million were also issued. This is one of the final naming rounds before the Fair Work Agency takes over enforcement in April 2026.

Change event: National Minimum Wage and National Living Wage increase April 2026 Effective 1 April 2026

What happened

On 19 March 2026, the government published the names of 389 employers found to have underpaid their workers in breach of National Minimum Wage and National Living Wage rules. This is Round 23 of the naming scheme, which has been running since 2011.

The employers were ordered to repay more than £7.3 million to approximately 60,000 workers. On top of the arrears, HMRC issued financial penalties totalling around £12.6 million.

The investigations covered underpayments dating from 2015 to 2022. Employers of all sizes were affected, from football clubs and nursery chains to professional services firms and high street retailers.

Employers named
389
Workers underpaid
Approximately 60,000
Total arrears owed
Over £7.3 million
Total penalties issued
Approximately £12.6 million
Investigation period
2015–2022
Published
19 March 2026

Who was named

The list includes household names across multiple sectors. The largest arrears were owed by:

  • ISS Mediclean Limited — £1,506,960 owed to 6,580 workers
  • Busy Bees Nurseries — £485,374 owed to 9,056 workers
  • Bupa Care Services — £441,440 owed to 8,810 workers
  • Hays Travel — £364,104 owed to 2,463 workers
  • Costa Limited — £149,851 owed to 2,759 workers
  • Norwich City Football Club — £99,022 owed to 1,152 workers
  • KPMG UK Limited — £13,088 owed to 59 workers
  • Harvey Nichols — £7,537 owed to 83 workers

Other named employers include Hovis, Sodexo, B&M Retail, Poundstretcher, Charlton Athletic FC, Amey Services, and JD Williams.

Why employers underpay — often without realising

Most underpayment is not deliberate. HMRC investigations consistently find the same compliance failures:

  • Deductions that reduce pay below the minimum (about 35% of cases) — requiring workers to buy or launder uniforms, deducting for tools, or charging for meals or accommodation beyond the permitted offset
  • Unpaid working time (about 31%) — pre-shift briefings, mandatory training, travel between sites during the working day, or time spent cashing up after a shift
  • Incorrect apprentice rates (about 16%) — paying the apprentice rate to workers who have completed their first year or turned 19, when they should move to the age-appropriate NMW or NLW band
  • Age band errors — failing to increase an employee's rate when they move into a higher age bracket
  • Salaried hours miscalculation — where a salaried worker's actual hours, averaged over the pay reference period, bring their effective hourly rate below the minimum

⚠️ Penalties for underpayment

Under section 19A of the National Minimum Wage Act 1998, HMRC can impose a penalty of 200% of the total arrears per worker, capped at £20,000 per worker. The penalty is reduced by 50% (to 100% of arrears) if paid within 14 days.

Employers who owe more than £500 in arrears are publicly named by the government.

In serious cases — wilful refusal to pay, falsifying records, or obstructing an investigation — criminal prosecution under section 31 of the Act can result in an unlimited fine and/or imprisonment.

HMRC can investigate back 6 years from the date of the notice of underpayment.

Fair Work Agency takes over enforcement from April 2026

This naming round is one of the last under HMRC's watch. The Fair Work Agency, created by the Employment Rights Act 2025, launches on 7 April 2026 — just 19 days after this announcement.

The Fair Work Agency will take over enforcement of the National Minimum Wage alongside Statutory Sick Pay, holiday pay, employment agency standards, and labour exploitation. It brings together functions previously split across HMRC, the Employment Agency Standards Inspectorate, and the Gangmasters and Labour Abuse Authority.

Employers should expect the same enforcement powers to continue under the new body, with a stated government objective of more joined-up and proactive compliance activity.

❗ What you should do now

Use this as a prompt to check your own compliance before the new April 2026 rates take effect on 6 April:

  • Audit all pay rates against the current NMW and NLW bands for each employee's age group
  • Check for hidden deductions — uniform costs, tool charges, or accommodation offsets that could pull effective pay below the minimum
  • Review working time — ensure all mandatory hours (training, briefings, travel between sites) are counted as paid time
  • Update apprentice rates — confirm that apprentices who have completed year one or turned 19 are on the correct band
  • Update payroll software before 6 April 2026 for the new rates: £12.71/hr (21+), £10.85/hr (18–20), £8.00/hr (under 18 and first-year apprentices)

ℹ️ Northern Ireland

The National Minimum Wage applies UK-wide, including in Northern Ireland. However, the Fair Work Agency's broader employment rights enforcement functions may differ in Northern Ireland where employment law is devolved. Check with the Labour Relations Agency for Northern Ireland-specific enforcement arrangements.

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