KPMG Among 491 UK Employers Named for Minimum Wage Violations

KPMG found itself on the wrong side of its own area of expertise when the UK government published its latest round of National Minimum Wage naming disclosures, placing the Big Four firm alongside Harvey Nichols and Norwich City FC among 491 employers cited for underpaying workers.

The October 2025 release of the government's naming scheme, which publicly identifies employers who have failed to meet National Minimum Wage obligations, carried a combined £10.2m in fines across the named companies. The violations were predominantly self-reported and corrected before or after disclosure, but the reputational weight of appearing on such a list carries consequences that extend well beyond the financial penalties.

The breaches follow patterns that payroll professionals will recognise. Apprentices paid at the wrong NMW rate, pay rates left unchanged after annual statutory uplifts, and working time that goes unrecorded, including unpaid training sessions, additional duties, and travel, account for the most common sources of non-compliance. Missed age-band changes, where a worker moves into a higher rate bracket but payroll is not updated accordingly, also featured among the risk areas identified in the round.

The October 2025 list included three public sector bodies, a detail that underscores how broadly compliance failures are distributed across sectors. Neither the luxury retail space nor professional services nor football clubs nor public institutions proved immune.

Labour responded to the disclosures by framing the named employers as examples of businesses failing their lowest-paid workers, with political criticism sharpening around the government's use of the naming scheme as an enforcement tool.

The timing of the disclosures matters beyond the immediate embarrassment. From April 2026, responsibility for National Minimum Wage enforcement moves from the Department for Business & Trade to the newly created Fair Work Agency, which is expected to arrive with broader investigative powers and a more aggressive posture on underpayment. Employers who have relied on self-correction catching issues before regulators do may find that approach carries significantly more risk under the incoming regime.

For KPMG specifically, appearing on this list creates an awkward public moment: the firm has actively communicated compliance guidance to clients and the broader market, including analysis of this very naming round. That guidance advises employers to ensure payroll and HR systems track pay and working hours accurately, to run regular audits across the workforce, and to maintain thorough documentation, since the Fair Work Agency may demand historical proof of compliance.

The practical lesson from the October 2025 round is that the most common violations are structural rather than deliberate: payroll systems that do not automatically update when statutory rates change, time-tracking arrangements that exclude categories of compensable work, and onboarding processes for apprentices that apply the wrong rate tier. These are fixable problems, but they require the kind of systematic internal audit that many organisations defer until a compliance event forces the issue.

With the Fair Work Agency set to assume enforcement powers in weeks, the window for voluntary correction ahead of a stricter investigative environment is closing.