Why Correct-Looking Pay Can Still Need A Closer Check

Minimum-Wage Underpayments

A Payslip Can Show The Right Hourly Rate While The Hours And Deductions Tell A Different Story.

The government named 389 employers over minimum-wage underpayments on 19 March 2026. That announcement covered more than £7.3 million owed to around 60,000 workers and £12.6 million in penalties. It is an important enforcement story, but it should not be presented as breaking news on 18 September.

A newer government announcement, published on 3 September, named nearly 660 employers. It reported around £4 million returned to more than 27,000 workers and £7 million in penalties. The two releases concern different naming rounds; their figures should not be mixed into one announcement.

Together, they raise a practical question for anyone reading a payslip: does the pay calculation cover all the time and payments that the law requires?

What The Naming Lists Establish

The releases record employers identified through minimum-wage enforcement. They establish the findings and sums reported for those rounds. They do not establish that every named employer used the same practice or that every underpayment was deliberate.

There is also a difference between arrears and penalties. Arrears concern money owed to workers. Penalties concern the financial sanction imposed on the employer. A headline combining the two as “wages stolen” would misdescribe the figures and imply intent that the totals alone cannot prove.

For a worker, repayment addresses a shortfall that has already occurred. For an employer, the more durable question is what process allowed it and how that process changes. A corrected payment is valuable, but a corrected system reduces the chance of the problem repeating.

The Advertised Rate Is Only The Starting Point

Government guidance explains that minimum-wage protection is expressed as an hourly rate but also applies to eligible workers paid through other arrangements, including salaries. Different calculation rules apply to different categories of work.

Hours matter. The guidance includes relevant working time such as required training and travel between work assignments, while distinguishing ordinary travel between home and work. A worker comparing only the rota’s headline shifts with the amount paid might therefore miss relevant time.

Take an illustrative hourly-paid worker receiving £520 for a week. If the relevant working time is 40 hours, that is £13 an hour. If it is actually 42 hours, the simple division becomes about £12.38. Whether that represents a legal underpayment depends on the applicable rate, pay reference period and statutory calculation; the example shows why accurate hours can change the answer.

Why Deductions Need Their Own Check

The government’s guidance on deductions warns that some deductions, including certain work-related expenses, can affect minimum-wage compliance. Other deductions receive different treatment. It would be wrong to assume that every difference between gross pay and the amount reaching a bank account is an unlawful underpayment.

Income tax, National Insurance and other authorised deductions can make take-home pay lower than gross pay without establishing a minimum-wage breach. The useful question is what each deduction represents and how the relevant rules treat it.

This makes a payslip a starting document rather than a complete investigation. A clear check may also require the contract, recorded hours, explanations of deductions and information about work-related costs. The names attached to payroll entries should match what actually happened.

Which Rate Applies?

The statutory rates from April 2026 are £12.71 an hour for people aged 21 and over, £10.85 for those aged 18 to 20, and £8 for eligible workers under 18. The apprentice rate is also £8, but eligibility depends on age and apprenticeship stage.

GOV.UK explains that the apprentice rate applies to apprentices under 19, or aged 19 and over during the first year of their apprenticeship. An apprentice aged 19 or over who has completed that first year is entitled to the applicable age rate.

Historical pay should be checked against the rules and rate applying at the relevant time. Applying today’s figure indiscriminately to an older payslip can create a misleading calculation in either direction.

What To Do If The Numbers Do Not Add Up

GOV.UK advises workers who suspect underpayment to raise the issue with their employer and, if it remains unresolved, request payment records in writing. Acas can provide confidential guidance, and complaints can be made to HMRC about an employer or employment agency.

Before asking for an explanation, organise the material by pay period. Record the hours in question, the amount paid and the particular deduction or missing time that concerns you. A precise discrepancy is easier to investigate than a general statement that the pay feels wrong.

The March and September lists are a reminder that compliance depends on the calculation as a whole. The right number printed beside “hourly rate” cannot make an incomplete record of work accurate.