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NMW obligations Concerns relating to NMW underpayments or unlawful deductions should be reported to HMRC, which enforces minimum wage legislation. We know that compliance with NMW will come under the remit of the Fair Work Agency (FWA) from 2027. Automatic enrolment duties If an employer is failing to meet their workplace pension obligations, such as not enrolling eligible workers or not paying contributions, this should be reported to The Pensions Regulator. Tax evasion or related concerns Issues such as deliberate underreporting of pay, off-payroll arrangements designed to evade tax or pay as you earn manipulation should be reported to HMRC under tax fraud or tax evasion reporting channels. Suspicious activity reports (SARs) Where you suspect deliberate evasion, fraud or activities that may fall under the Money Laundering Regulations, you may be required to file a SAR with the National Crime Agency. Modern slavery If you suspect someone is a victim of modern slavery, it’s important to report this through the relevant channels. Here’s one such avenue that can be used: https:// ow.ly/K2cZ50YMxZC. Right to work If an individual cannot produce the appropriate, original documents to prove their right to work in the UK (such as a passport, biometric residence permit or share code), specific legal and non- discriminatory steps must be taken to manage the situation and avoid heavy penalties. Find out more here: https:// ow.ly/4NOX50YMzXl. Future focus: increased enforcement Enforcement in the NMW space is already robust, and it will soon intensify. With the establishment of the FWA back in April
2026, scrutiny around holiday pay, SSP and other entitlements is expected to tighten further. This shift should create a more level playing field for employers, but it also means non-compliant payroll practices are more likely to be detected. For payroll providers, this underscores the importance of remaining vigilant, upholding professional standards and ensuring clients understand that compliance isn’t negotiable. We want to hear from you! There are many questions still to be answered in this space, and we want to open up the conversation and get others involved, so please do share your thoughts with us. You can contact Tracy at tracy@payrollsolutionsltd.co.uk or Lora at lora.murphy@cipp.org.uk . We’d love to hear from you.
Tracy Jerram MCIPP Commercial Director, Cox & Co Payroll Solutions Ltd.
Lora Murphy MCIPPdip CIPP Editor
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