Minimum wage April 2027: employer checklist

When the minimum wage rises, the obvious job is the payroll update: the new rates go into the system and the hourly staff move up with them. That leaves out the people whose pay is not set as an hourly rate at all.

A salaried manager whose salary was comfortably above the minimum three years ago, a trainee whose online course is done at home in the evening, a worker who buys their own black trousers for the job: each can fall below the new rate without any figure on the payslip changing. The checks below are for February and March 2027, so the April payroll is right first time.

As checked on 2 November 2026, the rates from April 2027 are announced, not yet law. On 28 October 2026 the government said it had accepted the Low Pay Commission's recommendations in full and announced increases from April 2027. GOV.UK announcement of 28 October 2026. Each year's rates are set by amending regulations; this year's came into force on 1 April 2026. The National Minimum Wage (Amendment) Regulations 2026. No instrument for the 2027 rates was on legislation.gov.uk on 2 November 2026, so check that it has been made, and its date, before the April payroll.

The minimum wage applies across the UK. This guide covers England, Scotland and Wales. Agricultural workers in Scotland and Wales can also qualify for a separate agricultural minimum rate of wages, fixed under the Agricultural Wages (Scotland) Act 1949 or the Agricultural Sector (Wales) Act 2014, and employers must keep records showing it was paid. Regulation 59. Enforcement of agricultural wages in Scotland and Wales remains with the devolved governments. Government guidance on the Fair Work Agency.

Put the new rates and the right start date into payroll

These are the hourly rates in force now and the rates announced for April 2027. GOV.UK minimum wage rates; The National Minimum Wage (Amendment) Regulations 2026; GOV.UK announcement of 28 October 2026.

Scroll across the table if needed.

The National Living Wage is the statutory minimum. The Living Wage Foundation's UK Living Wage and London Living Wage are voluntary benchmarks, and the announcement says so. If you pay one of them, that is your choice, not a legal floor.

The new rate starts with the first pay reference period that begins on or after the change date, not on the date itself. GOV.UK's example: if the rise takes effect on 1 April and a worker's pay period runs from the 16th of each month, they are on the old rate from 16 March to 15 April and on the new rate from 16 April. The same rule applies when a birthday moves someone into a higher age band. GOV.UK on calculating the minimum wage. The law behind it is regulation 4B: the rate is the one that applies on the first day of the pay reference period. Regulation 4B.

Two lists help here. The first is everyone who turns 18 or 21 between now and the end of the 2027 to 2028 year, with the pay period in which their rate changes. The second is your apprentices. The apprentice rate applies only to someone employed under an apprenticeship contract or agreement who is under 19 or in the first 12 months of that employment. Regulation 5. An apprentice aged 19 or over who has completed their first year is entitled to the rate for their age. GOV.UK minimum wage rates. Put each apprentice's start date and first anniversary in the payroll file, because the government's checklist names paying the apprentice rate after the first year, before an apprenticeship starts or after it ends as a common error. GOV.UK checklist for employers.

Recheck salaried staff against the hours they work

A salary is checked as an hourly rate too. For salaried hours work, the hours in each pay period are the basic annual hours in the contract divided by the number of payments: by 12 for monthly pay, 52 for weekly. You then divide the pay for the period by those hours and compare the result with the rate. GOV.UK on working hours for the minimum wage.

GOV.UK's own example shows how a salary drifts under. It takes £24,000 a year for 1,920 basic hours: £2,000 a month for 160 hours is £12.50 an hour, which cleared the 2025 to 2026 rate it was written for. The same contract is below the £12.71 in force now and the £13.21 announced for April 2027. At £13.21, 1,920 hours needs a salary of at least £25,363.20 for someone aged 21 or over. Do that sum for every salaried person: basic annual hours times the new rate, against their salary from April.

Then look at the hours they really work. Once a salaried worker who is not paid for extra hours has worked more than their basic annual hours in the calculation year, every extra hour has to be counted, from the pay period in which they pass their basic hours to the end of the year. The checklist names this as a typical cause of underpayment in the last pay reference period of the year. GOV.UK checklist for employers. A manager who regularly stays late and is paid close to the minimum is the case to check first.

The record is a short sheet per salaried person: basic annual hours, salary from April, the resulting hourly figure, and a note of how actual hours are tracked.

Count the hours that are easy to leave out

Hourly staff fall below the rate when time is worked but not recorded. For time workers, the hours that count include time at the workplace when required to be available, even if there is no work; standby or on-call time at or near the workplace, unless the worker is at home; travel on business and between clients; and time spent training. GOV.UK on working hours for the minimum wage.

Each of those maps to a habit worth checking:

• Training. Time spent training counts. For salaried workers, the guidance excludes only training the employer does not require that is done outside the hours they would otherwise work. Mandatory online modules belong in the hours.
• On call. A worker waiting at home to be called in is not entitled to the minimum wage for that time; once they arrive and are working or available for work, they are.
• Travel. Commuting does not count. Travel between one assignment and another does, as does travel from work to a training venue.
• Time at the edges of a shift. The checklist lists team handovers and security checks on entry and exit as time employers fail to pay. GOV.UK checklist for employers. A 30-minute early start each day and a weekly team meeting count; GOV.UK's worked example adds both to the hours.
• Sleep-in shifts. A worker on a sleep-in shift who has suitable sleeping facilities is entitled to the minimum wage only when awake for the purposes of working. If no suitable facilities are provided, the whole shift counts.

Pay conditions do not change this. GOV.UK states that contracts for payments below the minimum wage are not legally binding and the worker is still entitled to it. GOV.UK on who gets the minimum wage. Time workers must be paid at least the minimum wage for the time worked in each pay reference period, so training paid only if someone completes an assignment can leave the period in which they trained below the rate. A charge for required training, including one taken from final pay when someone leaves, reduces minimum wage pay too. GOV.UK on calculating the minimum wage.

Check what comes out of pay and what cannot count

The starting point is gross pay, and some of it does not count. Tips, service charges, overtime and shift premiums, allowances and expense reimbursements are among the payments left out of minimum wage pay. Where a higher rate is paid for overtime or nights, only the basic rate counts for time workers. GOV.UK on calculating the minimum wage.

Some deductions, and some payments a worker makes, reduce minimum wage pay. The same guidance lists the ones that come up most often:

• Uniform and dress codes. If you require specific items and do not supply them, any deduction for them always reduces minimum wage pay, and so does a worker buying them unless you reimburse the cost. Where you ask for generic clothing, such as a plain black T-shirt, GOV.UK suggests setting a reasonable amount you will reimburse.
• Equipment. Deductions or unreimbursed payments for protective equipment or other required equipment reduce pay.
• Salary sacrifice. Giving up salary for a benefit, such as extra pension contributions, a cycle scheme or parking, reduces pay for minimum wage purposes, and each further arrangement reduces it again.
• Accommodation. Living accommodation is the only benefit in kind that counts towards pay, and only up to the offset: £11.10 a day now, £11.53 announced from April 2027. The National Minimum Wage (Amendment) Regulations 2026; GOV.UK announcement of 28 October 2026. Charging more than the offset reduces minimum wage pay, and charges for gas, electricity, water or furniture are counted as part of the accommodation charge.

A deduction for a breakage the worker is contractually liable for, or for an agreed loan or advance of wages, does not reduce minimum wage pay. Whether the worker agreed to a deduction or benefits from it makes no difference to the others.

A practical approach is to ask your payroll provider for one report listing every recurring deduction and salary sacrifice, sorted by employee, and to rerun the hourly check for anyone within about a pound of the new rate. That margin is a working tolerance for the review, not a legal threshold.

Keep records that prove it, and correct any shortfall

The law requires records sufficient to establish that each worker was paid at least the minimum wage, in a form that can produce one worker's pay period in a single document, kept for six years from the end of the pay reference period following the one they cover. Regulation 59. GOV.UK advises recording actual hours, not only contracted hours, and lists items such as dates of birth, deductions, accommodation charges, travel and training time. It is your responsibility to prove the minimum wage was paid. GOV.UK on enforcing the minimum wage.

A worker who believes on reasonable grounds they have been underpaid can give you written notice asking to see the records, and you must produce them within 14 days or a later time agreed in that period. Section 10, National Minimum Wage Act 1998. GOV.UK states that if a tribunal upholds a complaint that the records were not produced, it awards the worker 80 times the hourly minimum wage. GOV.UK on enforcing the minimum wage. Our guide to the six-month tribunal time limit sets these records alongside the rest of a leaver file.

If the checks turn up a shortfall, pay it now rather than after April. Arrears are worked out at the current rate: divide the underpayment by the rate that applied at the time, then multiply by the current rate. A shortfall found after the new rates take effect is repaid using those rates. GOV.UK also describes a voluntary declaration route for arrears identified in a self-review; that page was last updated on 6 January 2026 and still names HMRC as the enforcer. GOV.UK on enforcing the minimum wage. Since 7 April 2026 the Fair Work Agency has enforced the minimum wage, and the government asks employers to review their record keeping. Government guidance on the Fair Work Agency.

Give the review to one person with a date in early March 2027: rates and change dates confirmed with payroll, the birthday and apprentice lists, the salaried hours sheet, the hours checklist, the deductions report, and a note of what was found and fixed. This does not remove the need to check the 2027 regulations once they are made. The Acas helpline on 0300 123 1100 gives free advice on the minimum wage. When you set pay for a new starter after April, our new starter checklist keeps the offer letter and payroll dates together.

Common questions

When does the minimum wage go up in 2027?

The government announced on 28 October 2026 that the new rates will apply from April 2027, and GOV.UK states that the rates change on 1 April every year. As checked on 2 November 2026 the regulations setting the 2027 rates had not been made. Each worker moves to the new rate at the start of their first pay period beginning on or after the change date. GOV.UK announcement; GOV.UK minimum wage rates; GOV.UK on calculating the minimum wage.

What is the minimum wage for 18 to 20 year olds from April 2027?

The announced rate is £11.27 an hour, up from £10.85. The rate for under-18s and apprentices is announced at £8.31, and the National Living Wage for those aged 21 and over at £13.21. These are announced figures until the amending regulations are made. GOV.UK minimum wage rates.

Do employers have to pay minimum wage for training time?

In most cases, yes. GOV.UK guidance lists time spent training among the hours that count for minimum wage purposes, and the employers' checklist names unpaid training time as a common error; for salaried workers, training the employer does not require that takes place outside their normal working hours does not count. A charge for training the employer requires, including one taken from final pay, also reduces minimum wage pay. GOV.UK on working hours for the minimum wage; GOV.UK checklist for employers; GOV.UK on calculating the minimum wage.

Does on-call time count for minimum wage?

Time on standby or on call at or near the workplace counts, unless the worker is at home. A worker waiting at home to be called in is entitled to the minimum wage once they arrive and are working or available for work. Sleep-in shifts follow separate rules on time awake for the purposes of working. GOV.UK on working hours for the minimum wage.