GOV.UK confirmed this week that 389 employers have been named in the government's latest National Minimum Wage enforcement round, ordered to repay a combined £7.3 million to around 60,000 workers found to have been underpaid. On top of that back pay, the same employers have been handed £12.6 million in penalties between them — a separate bill, on top of what they owe their staff, not instead of it. Employment Rights Minister Kate Dearden put the principle behind it plainly: "Nobody should finish a week's work and find they've been paid less than they've earned."
The enforcement itself was carried out by the Fair Work Agency, the single body that took over minimum wage enforcement when it began operating on 7 April 2026, consolidating powers that used to sit with HMRC's National Minimum Wage team. This naming round is one of the clearer early signals of how the new agency is using that consolidated power, and the current adult rate it is enforcing against is £12.71 an hour for workers 21 and over, £10.85 for 18 to 20-year-olds.
The list is not full of recognisable brands
A handful of the 389 names will register instantly — a football club, a national travel agent, a big facilities contractor among them. But scroll past the first page of the published list and the pattern changes completely. Nurseries appear over and over: Busy Bees Nurseries Limited owed £485,374.05 to 9,056 workers, but so did dozens of single-site childcare providers owing a few hundred or a few thousand pounds to a handful of staff. Care providers are the same story at both ends of the scale. So are hair and beauty salons, car washes, fish and chip shops, farm shops and taxi firms — the sectors the release itself flags as most affected are social care, sports, retail, hospitality, nurseries and manufacturing, and that list reads like a cross-section of ordinary small business, not a rogues' gallery of household names.
"Nobody should finish a week's work and find they've been paid less than they've earned." — Kate Dearden, Employment Rights Minister
That spread matters for how to read this list. It is tempting to assume minimum wage underpayment is mostly a story about large, process-heavy employers losing track of thousands of payslips. Some of it clearly is — ISS Mediclean Limited topped the list at £1,506,959.68 owed to 6,580 workers. But a one-person hairdresser, car wash or sandwich shop appears on the same list owing a few hundred pounds to a single worker, which means the Fair Work Agency is not just chasing payroll systems at scale. It is also catching the kind of small, informal underpayment that a business with no dedicated payroll person can drift into without ever deciding to short-change anyone.
How a business ends up on this list without meaning to
The published release does not break down what caused each case, but the routes into minimum wage underpayment are well documented and rarely involve a deliberate decision to pay someone less than the law allows. The most common ones: deducting the cost of a uniform or tools from pay in a way that drags take-home pay below the hourly minimum once the deduction is accounted for; not paying for time spent travelling between appointments or sites during the working day, which counts as working time for care workers, cleaners and mobile tradespeople even though it feels like a gap between jobs; rounding down hours on a timesheet rather than paying for the minutes actually worked; and getting an apprentice or a worker who has just turned 18, 21 or 25 onto the wrong age band because nobody updated payroll on their birthday. None of these require bad faith. All of them are the kind of small administrative drift that happens when payroll is handled alongside a dozen other jobs rather than owned by a specialist.
A worked example: how a small employer ends up repaying thousands without raising anyone's pay
Take an illustrative example — entirely fictional, used here only to show the arithmetic — of a seven-person hair and beauty salon paying all its staff at or just above the National Living Wage of £12.71 an hour on a standard 30-hour week.
The salon requires staff to buy a branded tunic at the start of each year, deducted from their first payslip at £45. On paper that looks like a minor admin charge. Under minimum wage rules, though, a deduction for a uniform the employer requires counts against the worker's pay for minimum wage purposes in the pay period it is taken — so a worker on exactly £12.71 an hour who has £45 deducted in one week has, for that week only, effectively been paid below the minimum wage, because the deduction brought their net hourly rate under the legal floor even though their contracted rate was compliant.
Multiply that by seven staff, each needing a replacement tunic once a year as they join or as uniforms wear out, and the salon has seven technical breaches a year — each one small, each one invisible on a normal payroll report, because the contracted hourly rate never changed. If a Fair Work Agency check goes back three years, as HMRC's equivalent checks historically have, that is 21 breach-weeks to recalculate and repay, plus the time cost of responding to the enquiry, plus the risk of appearing on the next naming round regardless of how small the total back pay turns out to be. The naming threshold is about the breach happening, not about the pounds involved — Mr R J Irving appears on this round's list for exactly one worker, as does Mrs Fiona Loughran's partnership and several other sole traders and small partnerships owing sums smaller than a single month's rent.
What actually changes once the Fair Work Agency names you
Two things happen that would not happen with a quiet, private correction. First, the business appears permanently on a public government list that journalists, trade press and — increasingly — customers can search, attached to the company's registered name and location, not an anonymised case number. Second, the back pay and the penalty are two separate bills: the back pay goes to the workers, in full, and the penalty is calculated on top of the arrears and goes to the Treasury, which is why the aggregate penalty figure in this round, £12.6 million, sits well above half of the £7.3 million back pay figure. Fixing an underpayment before an enforcement check finds it avoids both of those consequences — a business that spots and corrects its own error, and repays the worker voluntarily, is not the same case as one that gets found and named.
Three checks worth doing this week
List every deduction you take from pay, and check the date it lands against the date of the work it relates to. Uniform costs, till shortages, training costs and equipment charges are the deductions most likely to tip a compliant hourly rate below the legal minimum in the week they are taken, even when the contracted rate itself is fine.
If any staff travel between sites, appointments or branches during the working day, check whether that travel time is being paid. Time spent getting to your first appointment from home does not usually count, but time spent travelling from one client or site to the next, during the working day, generally does — and it is one of the most common gaps between what a rota says and what minimum wage law requires.
Run a birthday report. Anyone who has turned 18, 21 or 25 in the last twelve months needs their pay band checked against the current rate for their new age group, not the rate that applied when they were hired. A payroll system that was set up correctly on day one drifts out of compliance automatically every time an employee has a birthday, unless someone is actively checking for it.
The takeaway
Most of the 389 names on this list will never make a headline of their own — they are not Europcar or a listed housebuilder, they are a nursery in Rushden, a car wash in Loughborough, a fish bar in Herne Bay. The size of the business on the list ranges from £1.5 million owed by a facilities giant down to a few hundred pounds owed by a single trader, and the pattern that connects them is not scale, it is the kind of ordinary payroll drift — a uniform deduction, an unpaid travel gap, a missed birthday — that any small employer without a dedicated payroll specialist can fall into without ever intending to underpay anyone. The Fair Work Agency's naming round is a reminder that the fix is cheap and the exposure is not: an hour spent checking deductions, travel time and age bands this week is considerably less costly than a correction found for you, named publicly, with a penalty attached on top of the back pay.
Common questions
What's the actual penalty if the Fair Work Agency finds an underpayment?
Up to 200% of the arrears owed, capped at £20,000 per worker, on top of repaying the arrears themselves — and that penalty halves to 100% if you pay both the arrears and the reduced penalty within 14 days of the notice. So a business with £2,000 of arrears across a handful of staff could face up to £4,000 in penalties if it contests or delays, or £2,000 if it pays promptly within the 14-day window. The arrears are a separate bill from the penalty: the arrears go to the workers, the penalty goes to the Treasury, which is why the two published totals in any naming round never move in lockstep with each other.
How far back can the Fair Work Agency actually go when it checks my payroll?
Up to six years. Employers have been required to keep minimum wage records for six years since 1 April 2026 — it was three years before that — and enforcement can reach back over that whole period, not just the last twelve months. There's a sting in how the arrears get calculated too: HMRC's long-standing practice, which the Fair Work Agency has inherited, is to repay arrears at today's minimum wage rate rather than the rate that applied when the underpayment happened. An uniform deduction that shaved a few pence off an hourly rate three years ago gets repaid at £12.71 an hour now, not at the lower rate that was in force at the time, which is part of why small, old breaches can add up to more than they look like on paper.
Can a one-off uniform deduction really put me in breach, even if everyone's contracted rate is above minimum wage?
Yes, and it's one of the most common ways a compliant payroll drifts into breach without anyone deciding to underpay. Minimum wage law looks at what actually lands in a worker's pay in the week or month a deduction is taken, not just the contracted hourly rate. If a worker earning exactly the minimum has money taken off for a uniform, tools, or training the job requires, that deduction counts against their pay for minimum wage purposes in that specific pay period — so a technically compliant rate can dip below the legal floor for one week only, which is still a breach for that week. The fix is simple: either spread compulsory costs over enough pay periods that no single deduction pushes anyone under the rate, or pay staff enough above the minimum that the margin absorbs it.
Does unpaid travel time between jobs actually count as a minimum wage breach?
Often, yes, for anyone who travels between appointments or sites during the working day. Time spent commuting from home to a first appointment generally doesn't count as working time, but once someone is travelling from one client, site or branch to the next during their shift, that travel time usually does count — which means it has to be paid, and paid at a rate that keeps their average hourly pay for the day at or above the minimum. This catches care workers, cleaners, mobile hairdressers and tradespeople particularly often, because a rota built around appointment times rather than door-to-door time can look fully staffed and fully compliant while quietly dropping below the legal floor once the unpaid travel gaps are added back in.
If I find and fix an underpayment myself, is it treated the same as being caught by an enforcement check?
No — self-correction is treated far more leniently, which is exactly why it's worth doing the checks in this article before the Fair Work Agency does them for you. A business that spots its own error, repays the worker promptly and corrects the process going forward is not the same case as one a formal investigation catches: voluntary correction avoids the public naming, and a business that comes forward proactively is in a much stronger position when it comes to any penalty than one that only pays up after being issued a Notice of Underpayment. The naming round itself only lists employers who were found and formally notified, not ones who corrected an error before anyone came looking.
Buzz Accounting, a fixed-fee UK accountancy practice, has more on payroll for small employers.
