Research and analysis

National Minimum Wage Geographical Compliance Approach — Research

Published 29 May 2025

Prepared by BMG Research Limited for HM Revenue and Customs (HMRC)

Emma Osbourne (BMG Research Limited)

Research report number: 803

May 2025

The views in this report are the author’s own and do not necessarily reflect those of HMRC

1. Key findings

This research was undertaken on behalf of HM Revenue and Customs (HMRC) by BMG Research to evaluate the impact of the National Minimum Wage Geographical Compliance Approach (NMWGCA) education activity, which HMRC undertook in 2024.

A pre and post-campaign survey was undertaken among employers who are based in an area in the North West of England, their workers and agents.

Post-campaign, there was an improvement in levels of knowledge and understanding of the National Minimum Wage (NMW) rules, particularly among those who recalled receiving the letter from HMRC. Among employers and workers, there was more confidence in how to access information on the NMW.

Following the campaign, employers were less likely to report they fully understood the NMW rules and were also less likely to consider it easy to comply. This suggests employers now understand the NMW is more than just a pay rate and complying with NMW legislation is more complex than they originally thought.

Awareness of the NMWGCA education activity improved post-campaign. Although awareness did not wholly correlate with recall of the HMRC correspondence among agents, employers and workers. Not everyone who recalled receiving the letter was aware of the activity, while some of those who did not recall the letter were aware of it.

There was a lack of detailed knowledge of the NMW rules among all 3 groups, but post-campaign, there was greater awareness that there is more to paying and receiving the NMW than the hourly rate.

The findings suggest the campaign had a positive impact on levels of knowledge and understanding of the NMW rules among agents, employers and workers. However, there are still gaps in knowledge, particularly regarding specific details around the NMW regulations.

All 3 audiences were very positive about the helpfulness, usefulness and clarity of the information shared by HMRC in the correspondence about NMW rules.

Agents

Among agents, recall of the correspondence from HMRC relating to the NMWGCA education activity was greater among agents who had previously advised clients on NMW compliance, suggesting that the letter could have achieved greater saliency among those who have had to stay abreast of the rules and regulations.

Ratings of understanding of the NMW and confidence in knowledge and understanding of NMW regulations among agents improved post-campaign. Around two in five agents who recall receiving the letter felt more confident of their overall knowledge and understanding as a result of receiving the correspondence.

Most agents were aware of the potential impact of deductions in bringing workers’ pay down to below the NMW. However, post-campaign, there was still some lack of clarity for some about whether paying at NMW rate was enough for employers to be compliant with the regulations.

Specific knowledge of what deductions might impact compliance could be improved among agents, with sizeable minorities failing to identify some.

Although nearly all agents were aware there is a legal requirement to keep sufficient records, only two-thirds were aware that these records should be retained for up to 6 years and there was some uncertainty about the types of records that should be kept.

Employers

Among employers, relatively low awareness of the NMWGCA education activity compared with agents and workers could suggest a general lack of engagement with the subject. A minority of employers reported acting on the letter, with around one in ten of all employers having consulted their agent or accountant and one in seven taking some other action, such as reviewing pay or policies, as a result.

Among the few employers who arranged a free employer support call, all found it useful and felt it had benefited them.

Fewer employers post-campaign than previously felt they fully understood the rules and it was easy to comply with them, suggesting employers may still need more help in determining how it applies to their own business. However, this also suggests they may be more aware of the complexity of NMW rules following the campaign and thus more aware of potential gaps in their knowledge.

Similarly to the agents, nearly all employers were aware that they should be keeping records to demonstrate compliance with NMW regulations, and were also confident that they did so, far fewer indicated that they were aware of what records they needed to keep and that they should be retained for up to 6 years.

Workers

Few workers felt they knew a lot about the NMW following the campaign but the proportion that felt they did was higher among those who recalled receiving the letter.

Many workers were not familiar with the current NMW rate and this had not changed post-campaign. However, those who recalled the letter were more able to cite the correct rate for their age.

Most workers who travel with their work were aware they should be paid for this travel time, while fewer affected by mandatory training were aware that the time spent training for work outside of working hours could have an impact on their being paid in line with NMW rules.

Post-campaign, there was a substantial increase in workers feeling they know how to seek help if they needed it, that they can remain anonymous when reporting concerns to HMRC and that they can also report on behalf of someone else, particularly amongst those who recalled receiving the letter.

2. Background and objectives

This report presents the findings from the National Minimum Wage (NMW) Geographical Compliance Approach campaign evaluation, undertaken in 2024 by BMG Research on behalf of HM Revenue and Customs (HMRC).

2.1. About the NMW Geographical Compliance Approach

The National Minimum Wage Geographical Compliance Approach (NMWGCA) is a new compliance approach to risk-based enforcement activity using geography or sector to target those who may be at risk of paying, or receiving, below NMW/National Living wage.

The GCA uses a campaign of educational activity and employer support calls to support employers to remain compliant, without the punitive sanctions a NMW underpayment historically attracted. Therefore, representing a move towards a ‘promote and prevent’ strategy, with the aim of reducing the extent to which punitive measures are required.

The activity has allowed HMRC to assess all levels of risks and reach parts of the country where NMW complaints are traditionally low.

The GCA approach consisted of 6 stages, targeted at each of the 3 different audiences. The first stage targeted agents by offering awareness sessions. The second stage is targeted all employers, followed by a third stage where a reduced pool of employers (circa 2,500) received a second letter, either including a soft or hard nudge to contact HMRC for a support call. At stage 4 employers receive a support call and it was estimated around 13% of stage 3 employers (equating to circa 325 employers) would take this up. Stage 5 involved workers earning under £45,000 being sent a letter to advise them of common areas where underpayments can occur. Stage 6 will focus on employers from stage 3 who did not engage with the support call, and circa 250 will be selected for targeted enforcement activity, and following a full NMW investigation, will have traditional NMW sanctions applied to any underpayments identified.

It was estimated each stage would take between 4 and 6 weeks, although stages 5 and 6 are designed to be run concurrently. Therefore, the entire intervention activity could be completed within 7 to 8 months, with different audiences engaged at different stages in the process.

The GCA this study set out to evaluate was focused in an area in the North West of England.

2.2. Research objectives and approach

2.2.1. Research objectives

The research aimed to:

• quantify the impact of the NMWGCA on knowledge and compliance relating to NMW among employers, agents and workers
• provide evidence to understand the impact and efficacy of the GCA activity
• identify what behavioural changes and actions, if any, result from the approach
• identify whether GCA activity is increasing awareness and understanding of NMW obligations

2.2.2. Research approach

Initially HMRC contacted agents, employers and workers to give them the opportunity to opt-out of the research.

Where they did not opt out, employers and agents were invited to complete the pre-campaign survey by email where possible, and workers were invited to participate online via a QR code included in a letter. Participants were telephoned if no email address was available, or they could not complete the survey online.

For the post-campaign survey, all pre-campaign survey participants who agreed to be re-contacted were contacted via email.

2.2.3. Research timings

Fieldwork was undertaken on a phased approach, as shown below:

• agents: pre-campaign, 18 December 2023 to 28 February 2024, post-campaign, 22 May to 4 June 2024 and 27 August to 11 October 2024
• employers: pre-campaign, 11 January to 12 March 2024, post-campaign, 28 August to 11 October 2024
• workers: pre-campaign, 30 January to 5 March 2024, post-campaign, 28 August to 11 October 2024

There was a delay to the post-campaign survey as both communication from HMRC to employers and workers and survey fieldwork across all groups had to be paused when the 4 July General Election was announced. Communications to employers and workers resumed by the end of July 2024, and fieldwork resumed following that.

Among agents, the impact of the 4 July General Election pre-election period was more significant as HMRC had sent out letters in April 2024, prior to the General Election announcement. This contrasted with the employer and worker groups who were sent letters following the 4 July General Election. Therefore, there was a longer time lag between the communications being received and the post-campaign survey among agents compared with the employer and worker groups. This could have had a detrimental impact on levels of awareness and knowledge based on recall of the letter in the post-survey.

2.2.4. Responses

The table below summarises the number of responses achieved within each of the 3 audiences.

Sample Group	Pre-campaign completes	Post-campaign completes
Agents	228 (97 online, 131 telephone)	104 (55 online, 49 telephone)
Employers	399 (53 online, 346 telephone)	112 (15 online, 97 telephone)
Workers	309 (271 online, 38 telephone)	122 (118 online, 4 telephone)

Response rates at the pre-stage were as follows:

• agents: 18% (from 1,262 contacts)
• employers: 5% (from 7,948 contacts)
• workers: 10% (from 3,153 contacts)

Only those who responded at the pre-stage and agreed to be re-contacted at the post-stage, were invited to participate in the post-stage. Among this group, response rates were as follows:

• agents: 53%
• employers: 33%
• workers: 41%

2.3. This report

This report presents findings from each of the 3 audiences in separate chapters. It focuses on the impact of the HMRC communication, the post-findings, and how they compare with pre-findings amongst the returning participants. The pre or baseline findings are summarised within each section.

Sample bases are small, particularly in the post-stage survey and at a sub-sample level. Only differences between sub-samples or against the average that are statistically significant are referenced as significant. Where findings are not statistically significant but still discussed, this is noted. Where charts contain scales which do not sum to 100%, this is due to rounding of aggregated statistics.

3. Agents

3.1. Introduction

Pre-campaign fieldwork for agents was undertaken from 18 December 2023 to 28 February 2024, and post-campaign fieldwork was undertaken from 22 May to 4 June 2024, paused when the 4 July General Election was announced, and resumed from 27 August to 11 October 2024.

A total of 228 interviews were completed at the pre-stage (97 online and 131 by telephone), an 18% response rate, and 104 at the post-stage (55 online and 49 by telephone), a 53% response rate.

3.2. Overview of findings among agents

Agents were sent a letter offering support to assist employers to avoid common mistakes, which may lead to workers being underpaid, via a free virtual session. Agents were invited to contact HMRC to book an online session via Microsoft Teams.

Agents who had previously advised clients on NMW compliance were more likely to recall receiving the NMWGCA education activity correspondence. It suggests the correspondence had more of an impact among agents who already have to stay abreast of the rules and regulations.

Awareness of the NMWGCA activity increased post-campaign, with the NMWGCA letter most frequently cited as the source. This was reinforced by higher levels of awareness of the NMWGCA among those who recalled receiving the letter.

Ratings of understanding of the NMW and confidence in knowledge and understanding of NMW regulations among agents improved between the pre and post-stages. Around two in five agents who recalled receiving the letter felt more confident of their overall knowledge and understanding because of receiving the correspondence.

Most agents were aware of the potential impact of deductions taking workers’ pay to below the NMW. However, post-campaign, there was still some lack of clarity about whether paying at the NMW rate was enough for employers to be compliant with the regulations.

Specific knowledge of what deductions might impact NMW compliance could be improved among agents, with sizeable minorities failing to identify some deduction types.

Lack of specific knowledge is also apparent regarding the rules around employers keeping records to demonstrate their compliance. Although nearly all agents were aware there is a legal requirement to keep sufficient records, only two in three were aware these records should be retained for up to 6 years. There was also some uncertainty about the types of records employers should keep.

Most agents were familiar with the NMW rate for key groups of workers but there was less confidence in apprentice NMW rates.

The campaign appears to have had a positive impact on levels of knowledge and understanding of the NMW rules among agents. However, there are still gaps in knowledge, particularly regarding specific details around the NMW regulations.

Agents were very positive about the helpfulness, usefulness and clarity of the information shared by HMRC about the NMW rules.

3.3. Post-stage findings

3.3.1. Recall of letter

Around two in five agents (38%, equating to 39 agents) recalled receiving the letter, with recall higher among those who had ever advised their clients on NMW compliance (45%).

Of the 38% who recalled receiving the letter, 85% found it useful and 82% found it helpful, including 28% who found it very helpful.

Figure 1: Helpfulness of information in letter (post-stage agents)

Helpfulness of information in the letter	Percentage
Don’t know	3%
Not at all helpful	0%
Not very helpful	15%
Quite helpful	54%
Very helpful	28%

Sample base: 39 agents who recall receiving letter participating in post-stage QC03: How helpful was the information provided in the letter to you in clarifying the rules relating to National Minimum Wage?

Again, of the 38% who recalled receiving the letter, 38% had booked onto an online presentation or webinar, and 8% planned to do so. Where they had booked onto an online presentation or webinar, 60% found it very useful and 40% found it quite useful.

Of those who recalled receiving the letter, 31% took action with their clients as a result. This action included:

• advising their clients on the correct national minimum wage rate — either individually or via a standard mailing to all clients
• assisted them in reviewing employee contracts and pay rates
• advising clients of adjustments required to previous payments
• checking that their clients do not expect staff to provide tools or uniforms and that their clients pay staff for work travel (not including commuting)
• passing the information onto clients and informing their clients that HMRC are looking at whether businesses are compliant with NMW regulations.

Post-campaign, 59% of those who recalled receiving the letter had taken any action as a result, either by booking onto a webinar or with their clients, equating to 22% of all agents.

3.3.2. Awareness of GCA education activity

A third of agents (34%) were aware of the NMWGCA education activity pre-campaign and this increased to 42% post-campaign. Among those responding at both the pre and the post-stage, the uplift was 15 percentage points.

Among those aware of the education activity post-campaign, the most common source of awareness was the GCA letter (48%), with some mentioning word of mouth (11%), newspaper editorials (9%), and a small number mentioning other HMRC sources (website, emails, agent bulletins), or their clients.

At the post-stage, the letter overtook emails as the main source of awareness of GCA activity (emails cited by 62% at the pre-stage), highlighting the impact of the letter in raising awareness. This is reinforced by the fact that 64% of those who recalled receiving the letter were aware of NMWGCA education activity, compared to 29% of those who did not recall receiving it.

Figure 2: Source of awareness of GCA activity (post-stage agents)

Sources of awareness	Percentage
Letter from HMRC	48%
Word of mouth	11%
Newspaper editorial	9%
Poster	2%
Other	16%
Can’t recall	14%

Sample base: 44 agents aware of GCA activity participating in post-stage QC10: How did you first become aware of this wider GCA activity?

3.3.3. Understanding of NMW

Agents were asked to rate their understanding of the National Minimum Wage or National Living Wage in general on a 1 to 10 scale, where 1 represented no understanding at all and 10 represented an extremely good level of understanding.

The proportion rating their level of understanding at 9 or 10 increased pre to post, from 74% to 79%.

Figure 3: Understanding of NMW (pre and post-stage agents)

Stage	1 to 3 — Poor understanding	4 to 7 — Some understanding	8	9	10 — Extremely good understanding	Total
Post	0%	8%	13%	31%	48%	100%
Pre	0%	10%	13%	32%	45%	100%

Sample base: 104 agents participating in pre and post-stage Pre/Post QB01: How would you rate your understanding of the National Minimum Wage or National Living Wage in general, where 1 is do not understand it at all and 10 is extremely good level of understanding?

There are indications that receiving the letter has had an impact, with 82% of those who recalled receiving it rating their understanding as 9 or 10, compared to 77% of those who did not recall receiving the letter.

Most of those who rated their understanding as 10 at the pre-stage also rated their knowledge as 10 at the post-stage (91%) and 18% of those who rated their knowledge as 9 at the pre-stage increased this to 10 at the post-stage. Most of the remainder (79%) gave the same rating.

Of the 10 agents who rated their understanding at 4 to 7 at the pre-stage, 7 agents gave a rating of 4 to 7 at the post stage, while 3 gave a higher rating.

3.3.4. Confidence

Agents were also asked to rate their confidence in knowledge and understanding of the regulations and how it applies to employers to ensure they are compliant, and in being able to find and use the relevant guidance legislation to check clients’ compliance. Again, this was asked on a 1 to 10 scale, where 1 represented no confidence at all, and 10 represented an extremely high level of confidence.

Confidence in their knowledge and understanding of the regulations showed some change pre to post, with 56% rating their confidence at 9 or 10 at the post-stage, compared to 53% at the pre-stage.

Figure 4: Confidence in knowledge and understanding of NMW regulations (pre and post-stage agents)

Stage	1 to 3 — Little/no confidence	4 to 7 — Some confidence	8	9	10 — Extremely confident	Total
Post	0%	22%	22%	26%	30%	100%
Pre	1%	26%	20%	26%	27%	100%

Sample base: 104 agents participating in pre and post-stage Pre/Post QB02: How would you rate your current knowledge and understanding of the National Minimum Wage Act/Regulations 1998 and how it applies to employers to ensure they are compliant where 1 is not confident at all and 10 is very confident?

Overall, 16% of agents gave a higher rating of their confidence in their knowledge of the regulations at the post than at the pre-stage; 78% gave the same rating; and 6% gave a lower rating (equating to 6 agents, almost all of whom shifted down by 1 place on the rating scale).

There was no significant change in confidence in being able to find the relevant guidance and legislation to check their clients pre versus post campaign, but fewer rated their confidence at 9 or 10 at the post-stage compared with the pre-stage (69% compared to 73%).

Figure 5: Confidence in being able to find the relevant guidance and legislation to check compliance (pre and post-stage agents)

Stage	1 to 3 — Little/no confidence	4 to 7 — Some confidence	8	9	10 — Extremely confident	Total
Post	1%	11%	19%	23%	46%	100%
Pre	2%	12%	13%	26%	47%	100%

Sample base: all agents participating in pre and post-stage (104) Pre/Post QD01: How confident are you that you could find the relevant guidance and legislation to check your clients are compliant with their obligation under the National Minimum Wage Act 1998 where 1 is not confident at all and 10 is very confident?

Overall, 13% of agents gave a higher rating of their confidence in being able to find and use the relevant guidance legislation to check compliance at the post-stage, compared to the pre-stage, 76% gave the same rating and 12% gave a lower rating.

However, when the agents who recalled receiving the letter were asked at the post-stage whether they felt more, or less, confident of their overall knowledge and understanding of NMW as a result of the correspondence received, 38% felt more confident, with only 3% feeling less confident.

3.3.5. Awareness of correct rates

Approximately nine in ten agents (91%) were able to correctly identify the correct rate for workers aged 21 and over, and the remainder were aware when prompted.

Close to nine in ten correctly identified the rates for workers aged under 18 (88%), and apprentices in their first year (87%), and four in five (82%) were able to identify the correct rate for workers aged 18 to 20.

Agents were less knowledgeable of the correct rate for apprentices aged 21 and over after their first year of apprenticeship, and for apprentices aged 18 to 20 following completion (77% and 61% respectively responded with the correct rate).

Figure 6: Awareness of correct rates for different groups of workers (post-stage agents)

Groups	Correct rate	Incorrect rate	Don’t know	Total
Workers aged 21 and over (£11.44)	91%	5%	4%	100%
Workers under 18 (£6.40)	88%	2%	10%	100%
Apprentices in first year (£6.40)	87%	2%	11%	100%
Workers aged 18 to 20 (£8.60)	82%	7%	11%	100%
Apprentices aged 21 and over after 1st year of apprenticeship (£11.44)	77%	10%	13%	100%
Apprentices aged 18 to 20 following completion (£8.60)	61%	23%	16%	100%

Sample base: 104 agents participating in the post-stage (104), with the exception of the sample for 21+ (£11.44) which is 15 agents QB09: What do you think the current National Minimum Wage rate is in these circumstances, as of the 1st April 2024? QD01_NEW: The standard (21+ year olds) National Minimum Rate increased from £10.42 to £11.44 in April this year. Were you aware of this?

Over half of agents believed businesses are compliant if they pay the exact NMW rate (53%), or if they pay above the NMW rate (55%). Fewer of those who recalled receiving the letter believed that to be the case (49% and 51% respectively), suggesting they were a little better informed that there is more to being compliant than paying at the NMW rate.

Most agents (87%) were aware most deductions taken from a worker’s pay (apart from Tax/National Insurance), or payments a worker may make to employers in connection to their job, may put them at risk of receiving a pay rate below the NMW.

Again, while not significant, those who recalled receiving the letter were more likely to be aware of the impact of deductions and payments on workers’ pay rates (92%).

3.3.6. Awareness of circumstances that might impact NMW rates

Although 87% reported being aware of the impact of deductions on the NMW rate, a significant minority of agents failed to identify most scenarios that might impact on NMW rate compliance.

As shown in Figure 7, over three in four were aware that working additional hours on top of a shift and not receiving pay for those hours (79%) and not being paid for time spent in mandatory training (77%) might result in a worker receiving an hourly pay rate below the NMW.

Around two in three were aware that not being paid for travel time related to their job (rather than commuting) (67%) and deduction from pay for uniform items (65%) might impact on NMW rate compliance.

Approximately three in five (59%) were aware that deductions from pay for tools/equipment for use in their job role might impact NMW rate compliance. However, less than half (45%) were aware that workers having to pay for their uniform themselves or purchase items to meet a dress code might impact on NMW rate compliance, while only a third (36%) were aware that workers having to provide their own tools or equipment to do their job might have an impact.

A third incorrectly identified the following as instances that might impact on NMW rate compliance:

• not being paid for voluntary training (33%)
• deductions for Attachment of Earnings not including administration fees (21%)
• deductions for tax and National Insurance contributions (13%)

Further, 2% believed none of the listed options might impact on NMW rate compliance. Among those who recalled receiving the letter, significantly higher proportions were aware workers having to pay for their uniform themselves or purchase items of clothing to meet a dress code might impact NMW rates (59% compared to 37% of those who did not recall receiving the letter).The same was true in relation to workers having to provide their own tools/equipment to do their job (49% compared to 28%).

Figure 7: Awareness of circumstances that might impact NMW rates (post-stage agents)

Circumstances	All agents (104)	Where recall letter (39)
Working additional hours on top of a shift and not receiving pay for those hours	79%	87%
Not being paid for time spent in mandatory training	77%	87%
Not being paid for travel time, when they are travelling in connection with their job (not including commuting)	67%	69%
Deduction from pay for uniform items	65%	77%
Deduction from pay for tools/equipment for use in their job role	59%	69%
Workers having to pay for their uniform themselves or purchase items of clothing to meet a dress code	45%	59%
Workers having to provide their own tools/equipment to do their job	36%	49%

Sample bases in parentheses QB03_NEW: We would like to just test your knowledge of the National Minimum Wage rules and ask you, which of the following do you think might result in a worker receiving an hourly pay rate that is actually below the National Minimum Wage?

3.3.7. Keeping sufficient records

Almost all agents at the post-stage (99%) were aware that businesses are legally required to keep sufficient records to demonstrate they are paying their workers the National Minimum Wage rate. However, only 65% of agents were aware records should be retained for up to 6 years.

Almost all (99%) correctly identified pay slips showing breakdown of hours worked/pay received/commission as acceptable evidence for HMRC that businesses are complying with the NMW regulations. While a majority also correctly identified records of deductions (88%), date of birth and NINO of all employees (84%) and time sheets (78%) as acceptable forms of evidence for HMRC.

Figure 8: Awareness of acceptable forms of evidence to HMRC that businesses are complying with NMW regulations (post-stage agents)

Forms of evidence	Percentage
Pay slips showing breakdown of hours worked/pay received/commission	99%
Records of any deductions from pay	88%
Date of birth and NINO of all employees	84%
Time sheets	78%

Sample base: 104 agents participating in the post-stage QB13_NEW: Which of the following, do you think, are acceptable to HMRC as evidence that businesses are complying with National Minimum Wage regulations?

Incorrectly, 72% identified contract of employment, 29% staff handbook and 13% health and safety risk assessments as acceptable forms of evidence.

Awareness of acceptable forms of evidence were generally higher among agents who recalled receiving the letter:

• pay slips: 100% compared to 98%
• records of deductions: 92% compared to 86%
• date of birth and NINO: 87% compared to 82%

The only exception was regarding time sheets, identified by 74% of those who recalled receiving the letter as an acceptable form of evidence, compared to 80% of those who did not recall receiving the letter.

3.4. Baseline findings

3.4.1. Compliance

Prior to HMRC contacting agents as part of the NMWGCA campaign, nine in ten agents (89%) reported that NMW compliance is part of their standard HMRC compliance checks for their clients.

Understanding was rated as significantly higher among these agents who offer these checks, with 52% rating it as 10, compared to 10% of those who do not offer these NMW compliance checks as standard.

A third of agents at the pre-stage (35%) were aware that some or all of their clients had received any correspondence from HMRC regarding compliance activity and educating employers around common National Minimum Wage issues. This increased to 51% of those who reported being aware of GCA (26% of those who did not).

Close to half (47%) of those who were aware of correspondence their clients had received said these were letters or emails on compliance/rates, while 16% said that they had received compliance check notices.

One in twenty said their clients had received phone calls on compliance/inspections (4%), and the same proportion (4%) said they had received details on training/courses/webinars.

A quarter (28%) of this group felt that the information provided in the correspondence was very easy to understand, and a further 38% that it was quite easy to understand, while one in twenty (5%) said it was difficult.

Figure 9: Ease of understanding information provided to clients (pre-stage agents)

How easy or difficult it was to understand	Percentage
Very difficult	1%
Quite difficult	4%
Neither difficult nor easy	14%
Quite easy	38%
Very easy	28%

Sample base: 79 agents aware that clients have received correspondence participating in pre-stage QD07: How easy or difficult was the information provided in the correspondence to understand?

Two in five (42%) of all agents reported being asked by their clients to check they are NMW compliant. Of this group, the majority (82%) had been asked to do so more than once, with half (49%) having been asked more than twice.

Most commonly, agents reported being asked to check that pay rates are correct (45%), age-related rates of pay (23%) and to check for compliancy (15%).

Figure 10: NMW compliance checks requested by clients (pre-stage agents)

Checks requested	Percentage
Checking pay rates are correct	45%
Age-related rates of pay	23%
To check for compliancy	15%
Client requirement/request	6%
Apprentice’s pay rates	5%
New employee rates of pay	3%
When the change occurs/date of change	3%
Other	4%

Sample base: 95 agents who have been asked to check clients’ NMW compliance participating in pre-stage QC05: What specifically were you asked to check across all the occasions?

Overall, 82% of all agents felt it was easy to check clients’ compliance, including 44% who felt it was very easy. Just 5% rated it as difficult.

Figure 11: Ease of checking NMW compliance (pre-stage agents)

How easy or difficult it was to check compliance	Percentage
Very difficult	1%
Quite difficult	4%
Neither difficult nor easy	11%
Quite easy	38%
Very easy	44%

Sample base: 228 agents participating in pre-stage QC06: How easy or difficult is it to check your clients remain National Minimum Wage/National Living Wage compliant?

Agents in businesses with 20 or more employees were less likely to consider checking compliance to be easy (71% compared to 85% of those with fewer employees) but were more likely to consider it neither difficult nor easy (20% compared to 9% of those in smaller businesses) rather than to consider it difficult (6% compared to 5%).

3.4.2. Sources of information about NMW

At the pre-stage, 93% of agents said they sought information about NMW or NLW guidance and legislation via GOV.UK, and close to half (46%) reported going to Acas for such information. One in six (17%) reported going direct to the National Minimum Wage Act 1998, and 1in 8 (12%) the NMW manual.

Other sources cited by agents included internet search engines, HMRC website, professional bodies, payroll software, and newspapers.

More than two in five (44%) agents said it is very easy to find the information they need on GOV.UK, and a further 33% that it is quite easy. Fewer than one in ten (7%) considering finding information about the NMW to be difficult.

Figure 12: Ease of finding required information from GOV.UK (pre-stage agents)

How easy or difficult it was to find required information	Percentage
Very difficult	2%
Quite difficult	5%
Neither difficult nor easy	15%
Quite easy	33%
Very easy	44%

Sample base: 228 agents participating in pre-stage QD03: How easy or difficult is it to find what you need from the online information available on gov.uk?

Those who did not rate GOV.UK as very easy to use were asked what would make it easier to find the information they need on GOV.UK. Half (51%) of respondents provided no definitive response. Where they did, the most common suggested improvements were:

• better search tools/functionality (15%)
• more complex examples/scenarios (10%)
• more information available/access to information (9%)
• make it more user-friendly/simplify (6%)
• easier navigation (3%)

Close to half (46%) of agents reported they have attended a webinar on NMW, and this rose to 61% of larger agents (those with 20 or more employees). Where they had attended a webinar, most felt that the session was useful and all found the webinar they attended relevant and easy to understand.

A third (34%) of all agents reported awareness of HMRC’s large-scale geographical education activity to help employers get National Minimum Wage/National Living Wage right, most commonly via emails (62%), but also, to a lesser extent, in the media (12%).

3.4.3. Issues and challenges for employers

Agents were asked about the most common issues their clients have and what challenges they feel they have dealing with their clients about the National Minimum Wage/National Living Wage.

Close to half (45%) of agents reported their clients have no issues in this respect, while a higher proportion (57%) reported that they face no challenges when dealing with their clients regarding the NMW.

Where agents reported issues, these were, most commonly: changes according to birthday (10%), lack of knowledge of the rates (9%), affordability, including high rates (9%), and always ensuring the rates are correct (7%). Other issues were mentioned by 3% or fewer: change to salaries and yearly increase of rates (both 3%) and change in working hours and keeping it up to date (both 2%).

Figure 13: Issues faced by clients regarding NMW (pre-stage agents)

Issues faced	Percentage
Changes according to birthdays/age increase	10%
Not always aware of the rates/no knowledge of rates	9%
Affordability incl. high rates, different rates for different ages	9%
Always ensuring the rates are correct	7%
Change to salaries	3%
Yearly increase of rates	3%
Change in working hours	2%
Keeping it up-to-date	2%
Other	3%
Don’t know	8%

Sample base: 228 agents participating in pre-stage QC08: What are the most common issues your clients have regarding the National Minimum Wage/National Living Wage?

There were few differences by sub-groups of agents, although businesses with fewer than 5 employees were more likely than average to mention changes according to birthdays/age increase (15% compared to 10%). Agents who reported being aware of GCA were more likely than average to mention always ensuring the rates are correct (12% compared to 7%).

Where agents reported facing challenges when dealing with their employers, this was most commonly related to making clients aware of the rates and their responsibilities (12%) and ensuring rates/annual increases are up to date (9%). Other issues mentioned by 6% or fewer were: affordability/financial struggles (6%), changes according to birthday and lack of information provided by clients (both 4%), lack of communication (2%) and apprentices’ pay rates (1%).

Figure 14: Challenges when dealing with employers (pre-stage agents)

Challenges	Percentage
Changes according to birthdays/age increase	10%
Not always aware of the rates/no knowledge of rates	9%
Affordability incl. high rates, different rates for different ages	9%
Always ensuring the rates are correct	7%
Change to salaries	3%
Yearly increase of rates	3%
Change in working hours	2%
Keeping it up-to-date	2%
Other	3%
Don’t know	8%

Sample base: 228 agents participating in pre-stage QC09: What challenges do you feel you have dealing with your clients regarding the National Minimum Wage/National Living Wage?

4. Employers

4.1. Introduction

Pre-campaign fieldwork for employers was undertaken from 11 January to 12 March 2024, and post-campaign fieldwork was undertaken from 28 August to 11 October 2024 A total of 399 interviews were completed at the pre-stage (53 online and 346 by telephone), a 5% response rate, and 112 at the post-stage (15 online and 97 by telephone), a 33% response rate.

HMRC sent employers a letter advising they may need to check the rates at which they pay their workers. The letter provided information on the NMW regulations and detailed the NMW pay rates for different age groups and levels of apprenticeships. In addition, it signposted employers to other sources of information and advice to help them ensure they are compliant with NMW regulations.

4.2. Overview of findings among employers

Post-campaign, there was low awareness of the NMWGCA education activity among employers, even among those who recalled receiving the letter fewer than half were aware. This suggests some lack of engagement with the subject among employers.

However, awareness of the activity was significantly higher among employers who recalled receiving the letter, and the letter from HMRC was the most frequently cited source of awareness of it.

Recall of the letter from HMRC was higher amongst employers than agents, which may reflect the fact that it was largely aimed at reducing non-compliance among employers and it was more directly relevant to them.

Most employers had not acted on the letter, though this was partly because they did not recall receiving it. Of those who recalled the letter and employed an agent or accountant, one in three consulted their agent or accountant while just over one in four of those who recalled receiving the letter had taken some other action, such as reviewing pay or policies, as a result of receiving the letter.

Few employers who were offered the opportunity for a free employer support call had arranged one. Although those who had done so found it useful and felt it had benefited them. Employers who recalled the letter found the information useful and easy to understand, but the post-stage survey findings highlighted that fewer felt they fully understood the rules and that it was easy to comply post- campaign.

Nevertheless, many employers felt they have a better understanding and were more confident in their knowledge of the NMW rules post-campaign. Some were already very confident in how to find and use relevant guidance to check compliance and this changed very little post-campaign.

While knowledge of the NMW rates and the impact of deductions on workers’ pay rates improved post-campaign, employers still fell short of what would be desirable in terms of them being able to easily identify where they are non-compliant. Between 2-fifths and half of employers were not able to correctly identify factors that may impact on NMW pay rates post-campaign.

Similarly to agents, nearly all employers were aware that they should be keeping records to demonstrate compliance with NMW regulations and were also confident that they did. However, far fewer employers reported they were aware of what records they needed to keep and that they should be retained for up to 6 years.

4.3. Post-stage findings

4.3.1. Overview of findings among employers

Close to half (47%) of all employers recalled receiving the letter, and this was higher than average among employers with less than 10 employees (52%).

Most of this group (83%) recalled that this was in the form of a letter providing information about the National Minimum Wage, including a checklist. One in six (17%) recalled the letter requesting they arrange a free employer support call.

Among those who recalled receiving the letter, 92% found it useful, and 68% said they felt more confident of their knowledge and understanding of NMW as a result. No respondents felt less confident as a result of receiving the letter.

Four in five (81%) rated the information provided in the correspondence as easy to understand, including 30% who rated it as very easy to understand. Less than one in twenty (4%) found it difficult in any way.

4.3.2. Awareness of GCA education activity

Three in ten employers (29%) at the post-stage were aware of NMWGCA education activity; lower than the 49% of agents who were aware.

This was significantly higher among employers who recalled receiving the letter, compared to those who did not (45% compared to 15%).

As the higher level of awareness among those who recalled the letter suggests, a letter from HMRC was the most common source of awareness overall (52%; 58% among those who recalled receiving the letter) with other sources mentioned by 6% or less; TV editorial (6%), social media (3%), and word of mouth (3%).

Awareness of GCA education activity decreased as the size of the employer increased, from 33% of those with less than 10 employees, to 26% of those with 10 to 49 employees, and to 17% of those with 50 or more employees.

4.3.3. Actions taken

Of the 47% who recalled receiving the letter and had an agent or an accountant (33 employers), a third (36%) spoke to their agent or accountant specifically about the NMW as a result. This equates to around one in ten (11%) of all employers.

Of those that recalled receiving the letter, 28% had taken another action as a result, and a further 2% planned to, equating to 14% of all employers.

Of all employers, 4% planned to increase pay, and 3% planned to review policies.

4.3.4. Support calls

HMRC sent a letter to some employers inviting them to arrange a support call about NMW. Fewer than one in ten (8%) of all employers recalled receiving a letter asking them to arrange a support call with HMRC, 4% spoke to their agent/accountant and 4% arranged a call. All employers who arranged a call found it useful, easy to understand and it made them feel confident in dealing with future NMW obligations.

4.3.5. Understanding of NMW

Employers were asked to rate their understanding of the National Minimum Wage or National Living Wage in general on a 1 to 10 scale, where 1 represented no understanding at all, and 10 represented an extremely good level of understanding.

The proportion rating their level of understanding as 9 or 10 increased pre to post, from 55% to 63%, and the proportion rating their level of understanding as 4 to 7 halved from 21% to 10%.

Figure 15: Understanding of NMW (pre and post-stage employers)

Stage	1 to 3 — Poor understanding	4 to 7 — Some understanding	8	9	10 —Extremely good understanding	Total
Post	0%	10%	27%	23%	40%	100%
Pre	1%	21%	23%	22%	33%	100%

Sample base: 112 employers participating in pre and post-stage Pre/Post QB02: How would you rate your understanding of the National Minimum Wage or National Living Wage in general, where 1 is do not understand it at all and 10 is extremely good level of understanding?

Recall of the letter does not appear to have had an impact — 65% of those who recalled receiving the letter rated their level of understanding as 9 or 10, compared to 63% of those who did not recall the letter.

As was the case with agents, the majority of those who rated their understanding as 10 at the pre-stage also rated their knowledge as 10 at the post-stage (97%). However, 12% of those who rated their knowledge as 9 at the pre-stage increased this to 10 at the post-stage, with most of the remainder (80%) providing the same rating.

Overall, 21% gave a higher rating at the post-stage compared to the pre-stage, and 4% gave a lower rating.

4.3.6. Confidence

Employers were also asked to rate their confidence in knowledge of the National Minimum Wage Act and Regulations of 1998, and in being able to find and use the relevant guidance legislation to check compliance. Employers rated their confidence on a 1 to 10 scale, where 1 represented no confidence at all, and 10 represented an extremely high level of confidence.

The proportion rating their confidence in their knowledge and understanding as 9 or 10 increased from 58% at the pre-stage to 64% at the post-stage, and the proportion rating it as 1 to 7 decreased from 24% to 15%.

Those who recalled receiving the letter were significantly more likely than those who did not to rate their confidence in their understanding of the regulations as 9 or 10 (74% compared to 54%).

Figure 16: Confidence in knowledge and understanding of NMW regulations (pre and post-stage employers)

Stage	1 to 3 — Little/no confidence	4 to 7 — Some confidence	8	9	10 — Extremely confident	Total
Post	1%	14%	21%	20%	44%	100%
Pre	3%	22%	24%	13%	38%	100%

Sample base: all employers participating in pre and post-stage (112) Pre/Post QB01: Now moving on to questions about the National Minimum Wage… How confident are you with regard to your knowledge of the National Minimum Wage Act/Regulations of 1998 and how it applies to paying your employees, where 1 is not confident at all and 10 is very confident?

Most (88%) employers said they seek information about the relevant guidance and legislation via GOV.UK, 18% from Acas, and 5% from the NMW Manual.

Again, as was the case with agents, most of those who rated their confidence in their knowledge and understanding as 10 at the pre-stage also rated their confidence in this respect as 10 at the post-stage (93%). However, 33% of those who rated this as 9 at the pre-stage increased this to 10 at the post-stage, with the remainder (67%) providing the same rating.

Confidence in being able to find and use the relevant guidance legislation to check was largely consistent from pre (84% rated 9 or 10) to post- (87% rated 9 or 10), with 67% feeling extremely confident in this respect already.

Figure 17: Confidence in being able to find and use the relevant guidance and legislation (pre and post-stage employers)

Stage	1 to 3 — Little/no confidence	4 to 7 — Some confidence	8	9	10 — Extremely confident	Total
Post	0%	6%	7%	20%	67%	100%
Pre	0%	6%	10%	16%	68%	100%

Sample base: all employers participating in pre and post-stage (112) Pre/Post QB06: How confident are you that you could find and use the relevant guidance and legislation to check that what you pay your employees is compliant with National Minimum Wage legislation, where 1 is not confident at all and 10 is very confident?

While those who recalled receiving the letter were more likely than those who did not to rate their confidence in their knowledge about NMW regulations as 9 or 10 (74% compared to 54%), they were less likely to rate their confidence in being able to find and use the relevant guidance legislation to check compliance as 9 or 10 (79% compared to 93%).

Again, as was the case with agents, the majority of those who rated their confidence in being able to find and use the relevant guidance and legislation to check that what they pay their employees is compliant as 10 at the pre-stage also rated their confidence in this respect as 10 at the post-stage (91%), however, 17% of those who rated this as 9 at the pre-stage increased this to 10 at the post-stage, with the remainder (83%) providing the same rating.

4.3.7. Awareness of correct rates

There were low levels of awareness of the correct rate for all groups of workers, although employers were most able to correctly identify the NMW for workers aged 21 and over (60%).

Around a third correctly identified the rate for workers aged 18 to 20 (37%), workers aged under 18 (36%) and apprentices aged 21 and over after their first year of apprenticeship (33%). A quarter (27%) were able to correctly identify the correct rate for apprentices in their first year and 21% for apprentices aged 18 to 20 following the completion of the first year of their apprenticeship.

Employers who recalled receiving the letter were somewhat more likely to correctly identify the correct rate for each group of workers. Awareness of the correct rate for workers aged 21 and over increased to 62%; to 42% for with regard to the correct rate for both workers aged 18 to 20 and those under 18; to 36% with regard to the correct rate for apprentices in their first year, and to 28% for the correct rate for apprentices aged 18 to 20 after their first year of apprenticeship among those that recalled receiving the letter.

In all instances awareness of the correct rates were much lower among employers than agents.

Figure 18: Awareness of correct rates for different groups of workers (post-stage employers)

Groups	Correct rate	Incorrect rate	Don’t know	Total
Workers aged 21 and over (£11.44)	60%	26%	14%	100%
Workers aged 18 to 20 (£8.60)	37%	30%	33%	100%
Workers under 18 (£6.40)	36%	25%	39%	100%
Apprentices aged 21 and over after 1st year of apprenticeship (£11.44)	33%	17%	50%	100%
Apprentices in first year (£6.40)	27%	21%	52%	100%
Apprentices aged 18 to 20 following completion (£8.60)	21%	23%	56%	100%

Sample base: 112 employers participating in pre and post-stages QB06_NEW: What do you think the current National Minimum Wage rate is in these circumstances, as of the 1st April 2024?

At the post-stage, three in five (61%) employers believed that businesses are compliant if they pay the exact NMW rate, a significant decrease on the 83% of the same cohort who did so at the pre-stage. Of employers who said at the pre-stage that paying the exact rate was sufficient, 29% did not believe this was the case at the post-stage.

Similarly, 68% believed businesses are compliant if they pay above the NMW rate, again a significant decrease on the 92% of the same cohort who did so at the pre-stage. Again, of those who said at the pre-stage that paying above the rate was sufficient, 29% did not believe this was the case at the post-stage.

This suggests an improvement in knowledge of what it takes to be compliant.

Over four in five (83%) employers at the post-stage reported being aware that most deductions taken from a worker’s pay or payments they make to employers in connection to the job, apart from Tax/National Insurance, reduces their pay for NMW purposes and may bring what they receive below the amount they are legally due under National Minimum Wage rules. This was in line with the pre-stage (83%), and with agents (87%), and was the same among those who recalled receiving the letter (83%). The communication received from HMRC appears to have little impact on this.

4.3.8. Awareness of circumstances that might impact NMW rates

As shown in Figure 19, a sizeable minority of employers failed to identify most scenarios that might impact on NMW rates, with a majority failing to identify those which are less common.

Three in five employers were aware that working additional hours on top of a shift and not receiving pay for those hours (60%) and not being paid for time spent in mandatory training (59%) might result in a worker receiving an hourly pay rate below the NMW.

More than half were aware that not being paid for travel time related to their job (rather than commuting) (54%) and that deductions from pay for tools/equipment for use in their job (52%) role might have an impact on NMW compliance.

Less than half of employers believed deductions from pay for uniform items (46%) and workers having to pay for their uniform themselves or purchase items to meet a dress code (also 46%) might impact NMW rate compliance. Only a third (36%) were aware that if workers have to provide their own tools or equipment to do their job, that it might impact on NMW rate compliance.

In terms of the impacts identified by employers as possible impacts on NMW compliance a quarter incorrectly identified the following as instances that might impact on NMW rates:

• not being paid for voluntary training (28%)
• deductions for Attachment of Earnings not including administration fees (27%)
• deductions for tax and National Insurance contributions (26%)

In relation to deductions for Attachment of Earnings not including administration fees, those who recalled receiving the letter were significantly less likely than those who did not to incorrectly identify this as having an impact (17% compared to 36%).

Further, 10% believed none of the listed options might impact on NMW rates.

Figure 19: Awareness of circumstances that might impact NMW rates (post-stage employers)

Circumstance	Percentage
Working additional hours on top of a shift and not receiving pay for those hours	60%
Not being paid for time spent in mandatory training	59%
Not being paid for travel time, when they are travelling in connection with their job (not including commuting)	54%
Deduction from pay for tools/equipment for use in their job role	52%
Deduction from pay for uniform items	46%
Workers having to pay for their uniform themselves or purchase items of clothing to meet a dress code	46%
Workers having to provide their own tools/equipment to do their job	36%

Sample base: all employers participating in both pre and post-stages (112) QB04_NEW: We would like to just test your knowledge of the National Minimum Wage rules and ask you, which of the following do you think might result in a worker receiving an hourly pay rate that is actually below the National Minimum Wage?

4.3.9. NMW conditions and considerations

Job-related travel

At the pre-stage, 36% of employers reported employing workers who travel in connection with their job. Among this group, nine in ten (90%) reported workers are entitled to be paid for this time.

At the post-stage, close to half (44%) of employers reported employing workers who travel in connection with their job. In line with the pre-stage, of these, 90% were aware that their workers should be paid for this travel time, and 51% were aware that not being paid for this travel time might result in a worker being paid less than NMW rate. 

Mandatory training

At the pre-stage, 66% of employers reported that workers carry out mandatory training for work. Of these, 94% reported that workers are entitled to be paid for this training time. In line with this, at the post-stage, two in three (68%) employers reported that workers carry out mandatory training for work, and 95% were aware that their workers should be paid for this training time. Three in five (58%) were aware that not being paid for this training time might result in a worker being paid less than NMW rate.

Additional hours

At the pre-stage, 22% of employers said they expected workers to work additional hours on top of their shift. Of these, 91% reported that their workers are entitled to be paid for this additional time.

At the post-stage, three in ten (29%) of employers said they expected workers to work additional hours on top of their shift. Again, in line with the pre-stage, nine in ten (91%) were aware their workers should be paid for these additional hours, and 56% were aware that not being paid for additional hours might result in a worker being paid less than NMW rate.

4.3.10. Keeping sufficient records

At the pre-stage, 96% of employers who also participated in the post-stage were aware they are legally required to keep sufficient records to demonstrate they are paying their workers NMW pay rates, and 99% were confident that they did so, including 85% who were very confident in this respect.

When asked what type of records or information of employee pay and benefits they kept, close to half (45%) mentioned payslips (including pay/payments made), three in ten (29%) mentioned payroll and one in ten mentioned hours worked/time sheets/piece work records (12%), employment administration documents (contracts/pay review/promotion/offer letters) (11%) and P60/P45 (11%).

At the post-stage, half (50%) of employers were aware that records should be retained for up to 6 years, lower than the 65% of agents who were aware of this.

Almost all (99%) correctly identified pay slips showing breakdown of hours worked/pay received/commission as acceptable evidence for HMRC that businesses are complying with the NMW regulations. Although fewer, the majority also correctly identified records of deductions (89%), date of birth and NINO of all employees (77%) and time sheets (69%) as acceptable forms of evidence for HMRC, and this was largely in line with agents.

Incorrectly, 82% identified contract of employment, 39% staff handbook and 28% health and safety risk assessments as acceptable forms of evidence, and these were at somewhat higher levels than among agents.

Figure 20: Acceptable forms of evidence (post-stage employers)

Evidence	Percentage
Pay slips showing a breakdown of hours worked/pay received/commission	99%
Records of any deductions from pay	89%
Date of birth and NINO of all employees	77%
Time sheets	69%
Contract of employment (incorrect)	82%
Staff handbook (incorrect)	39%
Health and safety risk assessments (incorrect)	28%
Other (incorrect)	21%

Sample base: all employers participating in both pre and post-stages (112) To note: Incorrect examples of evidence that are acceptable are indicated in parentheses QB07_NEW: Which of the following, do you think, are acceptable to HMRC as evidence that businesses are complying with National Minimum Wage regulations?

Awareness of acceptable forms of evidence were generally higher among employers who recalled receiving the letter:

• pay slips: 100% compared to 98%
• records of deductions: 94% compared to 85%
• date of birth and NINO: 81% compared to 73%
• time sheets: 81% compared to 58%

Four in five (80%) at the post-stage were very confident that they keep sufficient records to demonstrate their compliance, in line with the same cohort at the pre-stage (85%), and a further 19% were quite confident.

4.3.11. Understanding of NMW implications for employees

At the post-stage, 59% of employers felt they fully understood how NMW applies to the people the business employs, a significant decrease on the 74% of the same cohort who did so at the pre-stage.

However, employers were more likely to say they mostly understood how NMW applies to the people the business employs (38% at the post-stage as compared to 23% at the pre-stage), rather than to say they understood it only a little or not at all (4% at the post-stage as compared to 3% at the pre-stage).

While 30% of those who felt they fully understood at the pre-stage changed their response to ‘mostly’ at the post-stage, 35% of those who felt they mostly understood at the pre-stage changed their response to ‘fully’ at the post-stage.

The apparent decline in understanding evidenced here among some employers, suggests that they may have become more aware that there is a degree of complexity to remaining compliant with the NMW rate and they were more uncertain as a result.

Figure 21: Extent to which employers understand how the NMW applies to people the business employs (pre and post-stage employers)

Extent to understanding	Post-campaign	Pre-campaign
Fully understand	59%	74%
Mostly understand	38%	23%
A little understanding	2%	0%
Not at all	2%	3%

Sample base: 112 employers participating in pre and post-stages Pre/Post QB03: Do you feel that you fully understand how the National Minimum Wage applies to the people your business employs?

4.3.12. Ease of remaining compliant with NMW requirements

The suggestion that some employers were less sure of their understanding of how NMW applies to the people the business employs post-stage, than pre-stage, is reflected in the significant decrease in the proportion who felt it was very easy to remain compliant with NMW requirements: 57% at the pre-stage to 35% at the post-stage.

There also seems to have been an increase in the perception that it is difficult to remain compliant with NMW requirements, with the proportion feeling it is difficult increasing from 4% to 8%.

Notably, those who recalled receiving the letter were significantly less likely to feel it is very easy to remain compliant than those who did not (25% compared to 44%), although more likely to feel it is quite easy (55% compared to 32%).

Overall, 78% felt it was very or quite easy to remain compliant at the post-stage, compared to 89% at the pre-stage.

Close to half (48%) of those who rated it as very easy to remain compliant at the pre-stage changed their response to a lower rating (less easy/more difficult) at the post-stage, as did 27% of those who rated it as quite easy at the pre-stage.

Figure 22: Ease of remaining compliant with NMW requirements (pre and post-stage employers)

How easy or difficult it is to remain compliant	Post-campaign	Pre-campaign
Very difficult	0%	1%
Quite difficult	8%	4%
Neither difficult nor easy	14%	6%
Quite easy	43%	32%
Very easy	35%	57%

Sample base: 112 employers participating in both pre and post-stages Pre/Post QB04: How easy or difficult is it, do you think, to remain compliant with National Minimum Wage requirements?

4.4. Baseline findings

At the pre-stage, 68% of employers reported employing an accountant, and 6% an agent, with 27% employing neither. Where they employed an agent (21 employers), most commonly this was to process the payroll/bookkeeping/accounts/tax (67%).

Where they employed an accountant, most commonly this was to process the payroll/wages (59%), taxation, including VAT returns (39%), general accounts/bookkeeping (34%), annual/year end accounts (29%), and providing financial advice including HMRC compliance, regulation changes (14%).

Of those who employ an accountant or agent, 75% expected them to provide advice in meeting their obligations as outlined in the NMW regulations and legislation.

A third (33%) of employers who employ an accountant or agent reported having spoken to their accountant/agent to ask questions specifically relating to NMW.

Two in three employers (67%) reported having read the NMW legislation to ensure their business is compliant, and this rose to 41% of those with an HR/payroll department.

Close to half (46%) said they had needed to look for specific information relating to the NMW at some point. Most commonly, the information sought related to checking pay rates/changes in NMW (43%), age-related rates of pay (36%) and apprentices’ pay rates (13%).

At the pre-stage, over nine in ten (93%) employers said they sought information about guidance and legislation that is relevant to the NMW/NLW via GOV.uk, in line with agents (93%).

However, significantly fewer employers than agents reported using Acas (10% compared to 46%), the National Minimum Wage Act 1998 (5% compared to 17%), or the NMW manual (2% compared to 12%).

Other sources cited by employers included: internet search including google, accountants, payroll/HR team, HMRC website, MSE website.

Close to half (49%) of employers said it is very easy to find the information they need on GOV.uk, and a further 32% that it is quite easy.

When those who did not rate GOV.UK as very easy to use were asked what they would like to see to make it easier to find the information they need on GOV.UK, two in three (68%) provided no definitive response. The most common suggested improvements were:

• easier navigation (10%)
• better clarity of information, including signposting (7%)
• information to be in simple terms/easier to understand including less jargon (6%)
• information to be concise including use of bullet points (5%)

A quarter (27%) of employers at the pre-stage reported received any correspondence from HMRC regarding compliance activity and educating employers around common National Minimum Wage issues.

Where they had received information from HMRC, this was most commonly updates on NMW via email/letter/booklets (51%) and invites to training/courses/webinars (17%). Four in five (80%) of those who received information from HMRC found it easy to understand, and the same proportion (80%) found it helpful, including 45% who found it very helpful.

Fewer than one in ten (7%) reported having attended a webinar on the NMW.

Two in three (65%) of all employers reported having read the NMW legislation to ensure that the business is compliant, and this increased with size, from 63% of those with less than 10 employees, to 81% of those with 50+ employees.

Those with an HR/Payroll function were more likely to report having read the legislation (75% compared to 61% of those without), as were those who employ an agent (81%) as compared to those who employ an accountant (64%).

Almost all (95%) employers were aware they are legally required to keep sufficient records to demonstrate they are paying their workers NMW pay rates, and 98% were confident that they do so, including 84% who were very confident in this respect.

5. Workers

5.1. Introduction

Pre-campaign fieldwork for workers was undertaken from 30 January to 5 March 2024, and post-campaign fieldwork was undertaken from 28 August to 11 October 2024.

A total of 399 interviews were completed at the pre-stage (53 online and 346 by telephone), a 10% response rate, and 112 at the post-stage (15 online and 97 by telephone), a 33% response rate.

HMRC sent workers a letter detailing the NMW rate they should expect to receive by age and, where applicable, by apprenticeship level. The letter provided a checklist of deductions that could potentially bring their pay rate down below the NMW rate, and signposted them to sources of advice and guidance, including specific details on how to report concerns.

5.2. Overview of findings among workers

Few workers felt they knew a lot about the NMW following the campaign but those who recalled receiving the letter were almost twice as likely to feel they know a fair bit about it, compared to those who did not recall the letter.

Workers who recalled the letter generally found it useful and most felt the information was clear.

Very few workers took action as a result of receiving the letter. However, it is expected action would have been appropriate or necessary for a minority of workers. There was a small increase in confidence in being able to find help and guidance on NMW rules post-campaign among workers.

Many workers were not familiar with their current NMW rate, and this did not change post-campaign. However, those who recalled the letter were more likely to cite the correct rate for their age.

There was a small improvement in knowledge that there was more to receiving the NMW rate than just being paid at that rate following the campaign. Those who recalled receiving the letter appeared more familiar with the potential impact of deductions on their hourly rate of pay.

Most workers who travel with their work were aware they should be paid for this travel time. Fewer affected by mandatory training were aware that the time spent training for work outside of working hours could have an impact on being paid in line with NMW rules.

Post-campaign, workers were more confident regarding how to obtain help and guidance on NMW rules. There was a substantial increase in workers feeling they know how to seek help if they needed it, that they can remain anonymous when reporting concerns to HMRC and that they can also report on behalf of someone else, particularly amongst those who recalled receiving the letter.

5.3. Post-stage findings

5.3.1. Recall of letter

A third of workers (34%) recalled receiving a letter about the National Minimum Wage/National Living Wage in recent weeks.

Half the workers who recalled receiving the letter (51%) found it useful, including 17% who found it very useful, while less than one in twenty (4%) did not find it useful.

Over nine in ten (91%) found it clear, including 54% who found it very clear.

Just 5% (2 workers) took action as a result of receiving the letter, with 1 of these workers contacting HMRC.

5.3.2. Understanding of NMW

Two in five workers (38%) at the post-stage felt they knew a fair bit or a lot about NMW, including 7% who felt they knew a lot.

This represents an increase compared with at the pre-stage among the same cohort, where 25% felt they knew a fair bit or a lot about NMW. This was driven by an increase in those who felt they knew a fair bit (31% compared to 21%), as there was only a small increase in those felt they knew a lot (4% to 7%).

A further three in five (59%) felt they knew a little, while 3% felt they knew nothing at all about it, which was a small improvement on the 7% who felt they knew nothing at the pre-stage.

Figure 23: Understanding of NMW (pre and post-stage workers)

Extent of understanding	Post-campaign	Pre-campaign
Nothing at all	3%	7%
A little	59%	68%
A fair bit	31%	21%
A lot	7%	4%

Sample base: 122 workers participating in pre and post-stages Pre/Post QB01: Now moving on to questions about the National Minimum Wage. How much do you feel you know about the National Minimum Wage, or National Living Wage as it is otherwise known?

Those who recalled receiving the letter felt more knowledgeable about NMW than those who did not — 56% felt they knew a fair bit or a lot, compared to 29%, with 12% feeling they knew a lot, compared to 4% of those who did not recall receiving the letter.

Of those who knew a little about NMW at the pre-stage,19% said they knew a fair bit at the post-stage, and 12% of those who said they knew a fair bit at the pre-stage said they knew a lot at the post-stage.

5.3.3. Confidence in finding help and guidance

Workers were asked to rate their confidence in being able to find help and guidance on NMW legislation to help them understand their entitlement to NMW on a 1 to 10 scale, where 1 represented no confidence at all, and 10 represented an extremely high level of confidence.

The proportion of workers who participated in both pre and post-stages who rated their confidence in their knowledge and understanding as 9 or 10 increased from 51% at the pre-stage to 55% at the post-stage, driven by an increase in those rating their confidence as 9.

The proportion giving a rating of 7 or below reduced pre to post from 32% to 28%.

Those who recalled receiving the letter were more likely to rate their confidence as 9 or 10 (71% compared to 47% of those who did not recall receiving the letter).

Figure 24: Confidence in finding help and guidance (pre and post-stage workers)

Stage	1 to 3 — Little/no confidence	4 to 7 — Some confidence	8	9	10 — Extremely confident	Total
Post	2%	27%	16%	18%	37%	100%
Pre	7%	25%	17%	11%	40%	100%

Sample base: 122 workers participating in pre and post-stage Pre/Post QC10: How confident are you that you could find help [or] guidance for yourself to help you understand your entitlement to the National Minimum Wage?

5.3.4. Awareness of correct rates

One in five workers (20%) were able to cite the correct NMW rate for their age, in line with the results for the same cohort at the pre-stage (also 20%). As was the case at the pre-stage, at the post-stage this increased with age, from none of those aged 16 to 22, to 18% of those aged 23 to 44, and to 25% of those aged 45 or more.

At the post-stage, around a third (37%) of those who had also responded at the pre-stage cited a rate higher than the correct option for their age (as compared to 30% at the pre-stage), and 46% cited a lower rate, again, in line with the pre-stage (48%).

Where the letter was recalled, 32% were able to cite the correct rate, compared with 14% of those who did not recall the letter.

Despite this, 76% of workers felt it was easy to find information about the NMW, including 36% who felt it was very easy, with 4% finding it difficult.

Almost all (91%) of those who recalled receiving the letter felt it would be fairly or very easy to find information, including 54% who felt it would be very easy, compared to 69% of those who did not recall receiving the letter who found it easy.

In addition, at the post-stage, 81% felt they knew where to go to find out about NMW, an uplift of 8 percentage points on the pre-stage, and this rose to 90% of those that recalled receiving the letter (as compared to 77% of those who did not).

At the post-stage, close to three in five (58%) workers felt they should know more about the minimum wage, a decrease on the 69% of the same cohort who did so at the pre-stage.

At the post-stage, more than three in five (62%) workers believed that they are receiving the NMW if they are paid the exact NMW rate, a small decrease on the 66% of the same cohort who did so at the pre-stage.

Similarly, while 74% of workers at the post-stage believed that they are receiving the NMW if they are paid above the NMW rate, this represented a small decrease on the 80% of the same cohort who did so at the pre-stage.

In both instances, levels were similar among those who recalled receiving the letter (61% and 83% respectively).

Thus, the letter appears not to have had a significant impact on awareness that there is more to NMW compliance than paying at a rate among workers.

5.3.5. Awareness of the impact of deductions

While only two in five (39%) workers were aware that most deductions taken from a worker’s pay or payments (apart from Tax/National Insurance) reduces their pay and might bring them under the NMW rate, this is a higher proportion than reported at the pre-stage (29%). The proportion that were aware of the impact of deductions on worker’s pay rates increased to 46% among those who recalled receiving the letter.

The letter appears to have had more of an impact on workers’ knowledge of how deductions affect whether they are receiving the right rate of pay.

At the pre-stage, 33% of workers reported travelling in connection with their job. While 66% of these were aware they are entitled to be paid for this travel time, 58% reported being paid for it.

At the post-stage, a quarter (25%) of workers reported having to travel for their work, and while the proportion who knew that they should be paid for this travel time rose to four in five (83%) of this group, a lower proportion, two in three (67%), reported being paid for it.

At the pre-stage, 80% of workers reported having undertaken training or learning at work in the last 12 months. Of these, 46% had done so outside of working hours. Half (51%) of this group were aware they are entitled to be paid for this training time and 54% reported being paid for this training time outside of working hours.

At the post-stage, two in five (38%) of those who train outside of working knew that they should be paid for this training time.

At the pre-stage, 50% of workers reported being required to wear a uniform or specified items. Of these, 31% reported paying for it themselves, and 3% said they have the expense deducted from their pay.

Less than 1% of employers reported taking payment from workers for uniform items and only 2% reported requiring workers to purchase items of clothing to meet a dress code.

At the post-stage, two in five (43%) reported their employer requires them to wear a uniform or specified items as part of a dress code, and a third (35%) of this group reported having to pay for this themselves.

At the pre-stage, 10% of workers reported they are expected to purchase their own equipment or tools to carry out their job, and 84% of these reported paying for equipment/tools themselves.

5.3.6. Reporting concerns

At the post-stage, 65% of workers said they knew how to seek help if they thought they were being paid less than the NMW, an uplift on the 46% of the same cohort who did so at the pre-stage.

Among those who recalled receiving the letter at the post-stage this rose to 78% (as compared to 58% who did not).

Workers were asked if they needed to report they were potentially underpaid, and what would be their preferred way of doing so.

Direct discussions with their employer were workers preferred way of reporting underpayment concerns at both the pre (74%) and the post-stage (69%). The proportion mentioning reporting to HMRC via an online form increased from 39% to 47% pre to post. Where workers recalled receiving the letter, 80% mentioned direct discussions with their employer, 46% completing an online form to HMRC, and 24% contacting Acas would be their preferred way of reporting concerns about their wage.

Figure 25: Preferred way of reporting concerns (pre and post-stage workers)

Ways	Post-campaign	Pre-campaign
Discuss with employer directly	69%	74%
Complete an online form to HMRC	47%	39%
Contact Acas	17%	18%
Would ask someone else to report it	7%	10%
Other	7%	5%
Wouldn’t do anything	2%	0%
Don’t know	4%	7%

Sample base: 122 workers participating in pre and post-stages Pre/Post QD05: If you needed to report that you were being potentially underpaid again/underpaid, what would be your preferred way of taking this forward/reporting your concerns?

In the pre-stage survey, participants were informed when HMRC receive a complaint or concern from someone about their wage, HMRC review the worker’s organisation to make sure everyone is being paid correctly. 60% of workers who went on to participate in the post-stage survey said then that this would make them more likely to report a concern to HMRC, 4% said it would make them less likely, and 29% said it would not make a difference.

Overall, 16% of workers who also participated in the post-stage reported potentially being prevented from reporting concerns due to fear of repercussions from their employer, and this rose to 23% among managers/professionals.

There was also a significant uplift from 36% to 65% pre to post in workers’ awareness that it is possible to remain anonymous from employers when reporting concerns to HMRC, and in their awareness that it is possible to report to HMRC on behalf of another person, from 19% to 41%.

When workers were asked which statements were true about the types of concerns that can be reported to HMRC, 57% at the post-stage knew they could report concerns about both a current and a previous employer up to 6 years ago (an uplift on the 39% of the same cohort who knew this at the pre-stage).

Figure 26: Knowledge of what can be reported to HMRC (pre and post-workers)

Statement	Post-campaign	Pre-campaign
You can report concerns to HMRC about a current employer only	7%	8%
You can report concerns to HMRC about a previous employer up to 6 years ago	8%	9%
You can report concerns to HMRC about both a current and a previous employer up to 6 years ago (correct)	57%	39%
None are true	4%	2%
Don’t know	24%	41%

Sample base: 122 workers participating in pre and post-stages To note: The correct statement is indicated in parentheses Pre/Post QD09: Which of the following statements are true?

5.4. Baseline findings

At the pre-stage, 37% of workers reported they have looked for information about the NMW, and this rose to 63% among those who knew what the NMW hourly rate is.

Of those who had looked for information, 79% reported using an internet search to look for information about the NMW, and 60% reported using a government website. Small proportions reported going to friends or family (11%), their employer (11%) or the Citizens Advice Bureau (4%) for guidance. Half (50%) said they found it very easy to find the information they were looking for, and a further 37% said that it was quite easy.

Close to three in five (58%) looked for information on the current national living or National Minimum Wage, and one in five (21%) for the age ranges for the current rates. Other types of information were mentioned by very few workers.

In almost all instances (99%), workers found the information they were looking for, and 87% said it was easy to find, including 50% who said it was very easy, and all said it was helpful. Of all workers, 72% said they knew where to go in future to find out more about NMW.

Although only 3% of workers said they had ever sought help because they thought they were being paid less than the National Minimum Wage, half (50%) said that they knew how to seek help if they thought they were being paid less than the NMW.

Appendix 1: sample profiles

The following tables show the profiles of the pre and post-stage samples for each audience. This is based on all respondents in both stages.

Table 2a: Profile of agents — Type of organisation

Type of organisation	Pre-campaign (228)	Post-campaign (104)
Accountant	25%	30%
SME	25%	23%
Specialist/boutique	21%	21%
1-person business	15%	17%
Large firm	7%	4%
Something else	1%	1%
Prefer not to say	5%	4%

Table 2b: Profile of agents — Number of UK employees

Number of UK employees	Pre-campaign (228)	Post-campaign (104)
0	3%	3%
1 to 4	34%	36%
5 to 9	24%	24%
10 to 19	18%	18%
20 to 49	9%	8%
50 to 99	3%	3%
100 to 249	1%	1%
250+	5%	5%
Unsure	3%	3%

Table 2c: Profile of agents — Number of UK-based clients

Number of UK-based clients	Pre-campaign (228)	Post-campaign (104)
Fewer than 5	<0.5%	1%
Between 5 and 10	2%	1%
More than 10	88%	95%
Unsure	2%	1%
Prefer not to say	8%	2%

Table 3a: Profile of employers — Type of organisation

Type of organisation/Sub-variable	Pre-campaign (399)	Post-campaign (112)
A single site business	86%	87%
A branch/subsidiary of a larger business	4%	3%
A head office with branches/subsidiaries elsewhere	9%	11%

Table 3b: Profile of employers — Number of paid employees

Number of paid employees	Pre-campaign (399)	Post-campaign (112)
1 to 4	37%	36%
5 to 9	26%	21%
10 to 19	18%	24%
20 to 49	13%	14%
50 to 99	4%	2%
100 to 249	2%	4%
250+	1%	0%
Unsure	<0.5%	0%

Table 3c: Profile of employers — Employer sector

Sector	Pre-campaign (399)	Post-campaign (112)
Primary	2%	1%
Production/construction	22%	21%
Distribution/catering	29%	21%
Business services	23%	26%
Public	10%	13%
Arts/entertainment	13%	19%

Table 3d: Profile of employers — Does the employer have a HR/payroll department?

HR/payroll department	Pre-campaign (399)	Post-campaign (112)
Yes	29%	29%

Table 4a: Profile of workers — sex

Sex	Pre-campaign (309)	Post-campaign (122)
Male (including trans male)	35%	34%
Female (including trans female)	62%	63%
Other	3%	3%

Table 4b: Profile of workers — age

Age	Pre-campaign (309)	Post-campaign (122)
16 to 18	1%	1%
19 to 22	7%	7%
23 to 34	25%	22%
35 to 44	28%	28%
45 to 54	17%	20%
55 to 64	18%	20%
65+	3%	2%

Table 4c: Profile of workers — Socio-Economic Group (SEG)

Socio-Economic Group (SEG)	Pre-campaign (309)	Post-campaign (122)
AB — higher and intermediate managerial, administrative, professional A	7%	5%
AB — higher and intermediate managerial, administrative, professional B	17%	24%
C1 — supervisory, clerical and junior managerial, administrative, professional	26%	29%
C2 — Skilled manual occupations	14%	11%
DE — Semi-skilled and unskilled manual occupations, lowest grade occupations D	13%	11%
DE — Semi-skilled and unskilled manual occupations, lowest grade occupations E	19%	16%
No SEG	3%	4%

Table 4d: Profile of workers — ethnicity

Ethnicity	Pre-campaign (309)	Post-campaign (122)
White	88%	91%
BME	11%	9%

Table 4e: Profile of workers — disability

With a disability	Pre-campaign (309)	Post-campaign (122)
Yes	9%	9%

Table 4f: Profile of workers — annual income

Pre-tax annual income	Pre-campaign (309)	Post-campaign (122)
Up to £20,000	33%	32%
£20,000 to £24,999	21%	20%
£25,000 to £49,999	39%	39%
£50,000 or more	5%	6%
Prefer not to say	4%	2%

Table 4g: Profile of workers — employee status

Working as an employee	Pre-campaign (309)	Post-campaign (122)
Yes	93%	93%
More than 1 paid job	Yes	9%	11%

Table 4h: Profile of workers — working status

Status	Pre-campaign (309)	Post-campaign (112)
Full time	67%	62%
Part time	30%	33%
Varies	2%	2%
Prefer not to say	1%	2%

Table 4i: Profile of workers — working hours

Hours worked	Pre-campaign (309)	Post-campaign (112)
0 to 5 hrs	*%	0%
6 to 10 hrs	2%	1%
11 to 20 hrs	10%	11%
21 to 30 hrs	9%	11%
31 to 40 hrs	69%	44%
40 hrs+	5%	5%
Don’t know	2%	3%
Prefer not to say	1%	25%
Worked additional hours	40%	35%

Table 4j: Profile of workers — main job

Main job	Pre-campaign (309)	Post-campaign (112)
Semi or unskilled manual work	18%	15%
Skilled manual worker	15%	11%
Supervisory or clerical/ junior managerial/ professional/administrative	34%	32%
Intermediate managerial/ professional/ administrative	22%	27%
Higher managerial/ professional/ administrative	7%	5%
Other	1%	5%
Prefer not to say	3%	6%