Today, HMRC published its list of employers found to have breached minimum wage laws. This is potentially the last list under the current HMRC-led system.

On 7 April 2026, the Fair Work Agency will be formally established and will eventually take over enforcement of the National Minimum Wage from HMRC. With less than three weeks to go until a new state enforcement regime is set up, now is a good time to pause and get ahead of things.

Today, HMRC published its list of employers found to have breached minimum wage laws. This is potentially the last list under the current HMRC-led system. The next one could be published by the Fair Work Agency. Today's naming list shows:

389 employers named.

7.3 million in arrears.

12.6 million in penalties.

Well-known brands appear on the list. But in most cases, employers haven't deliberately underpaid employees. They've been caught by technical non-compliance of the rules. For example:

• uniform costs, other deductions and salary sacrifice arrangements pushing pay below NMW;
• travel time, training or time on tasks before a shift starts not treated as working time when it should be; and
• pay that looks correct overall for the year, but isn't enough for inpidual pay reference periods – for example because of the way in which time off in lieu policies are operated.

Many of these issues are historic and have already been fixed. But that hasn't prevented public naming.

The reality of NMW compliance is that it is very easy to get caught out by the...

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