When the government published its latest list of employers who failed to pay the National Minimum Wage, it made headlines for all the wrong reasons. In October 2025, a total of 491 businesses were named, with arrears of more than six million pounds owed to over forty one thousand workers.
The report is part of the government’s National Minimum Wage Naming Scheme, which aims to increase awareness and discourage non compliance. However, many of the cases featured were not the result of deliberate underpayment. They were caused by common and easily avoidable administrative mistakes.
Understanding the National Minimum Wage
The National Minimum Wage sets the lowest amount that an employed person must be paid for their work. Rates vary depending on the worker’s age and their apprenticeship status. There are four categories: the National Living Wage for workers aged twenty one and over, the eighteen to twenty rate, the under eighteen rate and the apprentice rate.
Each April, the government reviews and often increases the minimum wage based on recommendations from the Low Pay Commission. It is the employer’s responsibility to ensure these new rates are applied correctly from the first pay period following the increase.
What Went Wrong in Round Twenty Two
The October 2025 list, referred to as Round Twenty Two, covered breaches that took place between 2013 and 2023. Employers across the country were included, with the hospitality and retail sectors particularly affected. Well known names such as Euro Garages, Red Contract Solutions and CSG FM featured in the list.
The accompanying Educational Bulletin revealed three key reasons employers underpaid their staff.
Apprentices Paid the Wrong Rate
This was the most common issue and accounted for twenty eight per cent of cases. Employers either continued paying the apprentice rate beyond the first year, failed to increase pay when apprentices turned nineteen, or misclassified staff as apprentices when they were not.
These mistakes often arise because key dates are not tracked. Something as simple as a diary reminder or a payroll alert can prevent these errors. Employers should also remember that once an apprenticeship is completed, the individual must be moved to the higher rate appropriate for their age.
Missing the Annual Increase
Twenty seven per cent of breaches were due to employers not applying the updated minimum wage rates each April. Timing was often the problem. Many businesses applied the new rate based on the payday rather than the pay reference period.
For example, if an employer’s pay period runs from the tenth of one month to the ninth of the next, the new rates apply from the tenth of April, even if payday falls later. Missing this detail can create an unintentional breach.
Not Paying for All Working Time
Fifteen per cent of employers failed to pay correctly for all working time. This included unpaid time spent on training, travelling between sites, pre shift and post shift duties, or trial shifts. Some employers also rounded clock in times or made late payments, which can technically bring wages below the minimum during a pay period.
To remain compliant, employers must keep accurate records of all hours worked. These records must show clearly that every worker is receiving at least the minimum wage for each pay period. Since April 2021, employers must retain these records for at least six years.
How HR Chest Can Help
The findings highlight that underpayment is rarely deliberate. It is usually a sign that systems and records are not keeping up with statutory requirements. HR Chest can make this easier for employers by providing timely updates on all statutory rate changes and tools to help track birthdays, start dates, apprenticeship milestones and pay points. Members can also access support on creating and organising employee personnel files so that all key information is logged and easy to reference.
These simple processes reduce the risk of missing vital dates and help keep payroll accurate throughout the year.
Lessons for Employers
The latest data is a reminder that a few small oversights can lead to very costly consequences. Public naming, reputational damage and the need to repay arrears can all be avoided with strong internal systems.
Employers should build birthdays, apprenticeship milestones and annual minimum wage changes into their payroll processes. They should also review how working time is recorded and make sure that all training, travel and preparation time is included.
If you would like support reviewing your pay processes or want help ensuring full compliance with the National Minimum Wage, ECHR can assist.