National Minimum Wage compliance from 1 April 2026
Practical guidance for employers with mixed workforces
From 1 April 2026, the UK National Living Wage and National Minimum Wage rates increase across all age bands. For businesses employing a mix of salaried staff, hourly workers, part-time employees, apprentices and younger workers, these changes bring heightened compliance risk if payroll arrangements are not reviewed carefully.
At Amlink, we work with employers across the Midlands and beyond to ensure wage compliance is accurate, defensible, and HMRC-ready.
Who this applies to
Minimum wage rules apply to almost all workers, including:
- Full-time and part-time employees
- Monthly salaried and hourly paid staff
- Zero-hours and casual workers
- Apprentices
- Workers under 21
- Workers provided with accommodation
- Temporary, seasonal and agency workers
Where different worker types are employed, each individual must be assessed separately, and compliance must be met in every pay reference period.
Key compliance considerations from 1 April 2026
Paying the correct rate
Workers must be paid at least the correct statutory rate based on:
- Their age
- Whether they qualify for the apprentice rate
- Any change in age band, which takes effect from the birthday itself
Delays in applying age-related increases are a frequent cause of underpayment.
Pay reference periods matter
Minimum wage compliance is tested per pay period, not annually.
Even where annual salaries appear compliant, underpayments can arise due to:
- Reduced hours in a particular month
- Unpaid time worked
- Deductions or salary sacrifice arrangements
This is particularly relevant for monthly-paid staff and variable hours workers.
Deductions and work-related costs
Certain deductions reduce pay for minimum wage purposes, including:
- Uniforms or work clothing
- Tools and equipment
- Training costs
- Payroll deductions linked to work requirements
Even lawful deductions cannot reduce pay below the minimum wage in the relevant pay period.
Salary sacrifice arrangements
Salary sacrifice schemes must be reviewed carefully where staff are close to minimum wage:
- Pay is assessed after sacrifice
- Many schemes are not compatible with minimum wage workers
- Employers remain liable even where participation is voluntary
Recording working time accurately
Minimum wage calculations include all working time, not just contracted hours. This may include:
- Mandatory training
- Opening and closing duties
- Required travel between sites
- Certain standby or on-call time
Poor time recording is one of the most common causes of HMRC challenges.
Accommodation offset
Where accommodation is provided:
- Only the statutory accommodation offset can count towards minimum wage pay
- From 1 April 2026, this increases to £11.10 per day (£77.70 per week)
- Any excess charge must not reduce pay below the minimum wage
Apprentices
The apprentice rate applies only where the apprentice is:
- Under 19, or
- 19 or over and in the first year of their apprenticeship
After this point, the full age-appropriate minimum wage applies, even if the apprenticeship continues.
Enforcement and penalties
Minimum wage enforcement is becoming more robust. Employers face:
- HMRC investigations and arrears assessments
- Penalties of up to 200% of underpaid wages
- Public naming for non-compliance
Crucially, intent does not matter — accidental errors still result in penalties.
How Amlink can help
For businesses employing a wide range of worker types, we provide:
- Minimum wage compliance reviews
- Payroll and deduction audits
- Apprenticeship pay checks
- Accommodation offset reviews
- Practical advice aligned with HMRC expectations
Our aim is to ensure your payroll is fully compliant, commercially practical, and future-proofed.
Speak to us
If you would like to review your payroll arrangements ahead of 1 April 2026, or if you are unsure whether your current setup remains compliant, contact Amlink for a confidential discussion.
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