National Minimum Wage (NMW) Compliance Project

The organisation initiated a National Minimum Wage compliance review after internal audits highlighted potential risks around timekeeping, deductions, and pay accuracy.

The organisation initiated a National Minimum Wage compliance review after internal audits highlighted potential risks around timekeeping, deductions, and pay accuracy.

The organisation initiated a National Minimum Wage compliance review after internal audits highlighted potential risks around timekeeping, deductions, and pay accuracy.

About the project

With potential exposure to HMRC investigation, the project required a robust audit, remediation plan, and long-term controls to prevent recurrence.

With potential exposure to HMRC investigation, the project required a robust audit, remediation plan, and long-term controls to prevent recurrence.

With potential exposure to HMRC investigation, the project required a robust audit, remediation plan, and long-term controls to prevent recurrence.

Date:

Jan 30, 2025

Objectives

  • Conduct a full audit of payroll, working time, and deduction records

  • Identify areas of potential NMW non-compliance

  • Rectify historical errors and strengthen future controls

  • Improve accuracy of timekeeping, particularly around unpaid time and uniform deductions

Bianca turned a complex compliance risk into a clear, manageable programme. Her attention to detail and cross-team leadership prevented future issues and strengthened our controls.

Head of Payroll & Compliance

Role & Responsibilities

  • Led a cross-functional team involving Payroll, HR, Legal, and Finance

  • Oversaw data extraction, cleansing, and analysis across multiple systems

  • Built risk matrices and compliance dashboards to highlight potential breaches

  • Presented findings and remediation recommendations to executive leadership

  • Coordinated direct employee remediation, policy updates, and future prevention controls

Challenges

  • Fragmented timekeeping data across legacy systems

  • Historical manual deductions lacking clear documentation

  • Identifying hidden or indirect underpayment risks (e.g., pre-shift tasks)

  • Tight reporting deadlines tied to audit requirements

Solutions Delivered

  • Conducted detailed pay/time reconciliation for all impacted employees

  • Created a centralised compliance dashboard with real-time alerts

  • Implemented new policies for deductions, uniform costs, and timekeeping accuracy

  • Worked with Payroll and Ops to redesign sign-in/out processes

  • Delivered training to managers on NMW requirements and audit expectations

Outcomes & Impact

  • Full visibility of NMW exposure and high-risk employee groups

  • Eliminated historic underpayment cases and avoided HMRC penalties

  • Introduced long-term controls, reducing compliance risk for future periods

  • Improved payroll accuracy and consistency across the organisation

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