Holland & Barrett failed to pay £153,079.29 to 2,551 workers following the October 2025 government naming round for failing to meet legal pay standards.
Now, despite them resolving these legacy issues in 2022, the case highlights how easily routine retail practices can lead to a Holland & Barrett minimum wage underpayment. Many firms struggle to maintain compliance when mandatory training or uniform costs silently erode hourly rates.
Today, we will analyze the technical causes behind these payroll failures and outline the proactive steps necessary to navigate the increasingly strict UK enforcement landscape.
The Holland & Barrett Minimum Wage Underpayment Case and Its Financial Reality
Holland & Barrett Retail Ltd was named in the October 2025 UK government enforcement round for failing to pay £153,079.29 to 2,551 workers. The historical underpayments related to uniform requirements, unpaid training and time spent preparing for shifts, highlighting payroll risks for large retail workforces.
Breakdown of the £153,000 Arrears for 2,551 Employees
The government confirmed £153,079.29 in underpayments affecting 2,551 workers during the October 2025 naming round. Holland & Barrett stated that the arrears were repaid in full after the issues were identified and that the problems were resolved in 2022. The later public naming illustrates how historic payroll failures can remain visible long after remediation.
The impact was felt across the entire UK workforce. Large retailers currently face intense scrutiny regarding pay parity and legal standards. This naming policy serves as a clear warning to other major corporate entities.
The government maintains a strict stance on minimum wage thresholds. High-profile cases like this ensure that workers eventually receive their legal dues.
We must consider how these figures align with broader minimum ages in the EU since maintaining compliance is a constant challenge for international brands.
- Total arrears identified: £153,079.29
- Number of staff members impacted: 2,551
- Primary causes: Uniform costs and unpaid training time
- Current pay status: Approximately 5% above the National Living Wage
Historical Context and the 2022 Resolution of Legacy Issues
The violations occurred between 2015 and 2021. These were legacy issues identified during a detailed audit. The company claims these errors were purely historical and do not reflect current practice.
Management emphasized that the payroll errors are quite old. They stated the problem was fully resolved in 2022. All affected staff members were reimbursed three years ago.
While the naming happened in 2025, the remediation was proactive. This delay in government reporting can damage brand reputation long after the fix. Companies must manage the narrative around past compliance failures. Transparency is essential for maintaining employee trust.
3 Technical Causes for the Holland & Barrett Minimum Wage Underpayment
But while the numbers are clear, the actual mechanics of how these underpayments occurred involve specific, seemingly routine retail practices.
Hidden Costs of Uniform Requirements and Specific Footwear
Mandatory shoe purchases significantly reduced effective hourly rates. When a worker is required to buy specific footwear, that cost is deducted from their pay, which often pushes wages below the legal limit.
Under GOV.UK classifications, job-related deductions are often deemed non-compliant. Any expense required for the role counts against the minimum wage. Retailers often overlook these small financial shifts, yet the burden should never fall on low-wage staff. These technicalities remain a primary cause of legal friction.
| Deduction Type | Compliance Risk | Impact on Net Pay | Recommendation |
| Uniforms | High risk | Direct hourly reduction | Provide free kit |
| Safety Gear | High risk | Initial pay dip | Employer funded |
| Training Time | Medium risk | Unpaid hours gap | Full pay policy |
| Equipment Maintenance | Medium risk | Variable reduction | Policy change |
These small deductions create massive cumulative liabilities for employers, shifting a significant financial burden onto retail staff.
Unpaid Training Hours and Shift Preparation at Distribution Sites
Mandatory training completed outside employees’ scheduled hours can create minimum wage compliance issues when that time should legally be treated as working time. Even when each instance involves only a small number of minutes, the impact can become significant when repeated across a large workforce.
At the Burton hub, employees also spent time preparing for their shifts, including completing security checks and attending briefings. Where these activities are required as part of the job, the time may need to be included when calculating whether employees have received at least the applicable minimum wage.
Small unpaid increments can therefore have a substantial cumulative effect. When thousands of employees regularly perform unpaid training or pre-shift tasks, even a few minutes per shift can result in significant arrears over time. Payroll audits should account for these activities when assessing compliance and identifying potential underpayments.
Effective oversight also requires employers to review how payroll responsibilities are managed across different locations and teams. A clear approach to centralized and decentralized payroll can help maintain consistent controls, while regular audits of historical practices can identify and correct potential underpayments before they become larger compliance issues.
How to Prevent a Holland & Barrett Minimum Wage Underpayment in Your Firm?
Avoiding these pitfalls requires a proactive shift in how payroll teams audit deductions and track working hours. Transitioning from legacy systems to modern compliance standards is no longer optional for UK businesses.
Identifying Deductions That Breach the Hourly Threshold
Payroll systems should be evaluated for automatic triggers related to equipment. Uniform costs must be monitored against the hourly rate, and systems should flag any worker nearing the minimum threshold. Manual overrides are often necessary for compliance to prevent accidental breaches during high-volume periods.
Regular audits of net pay versus gross pay are essential, focusing particularly on workers at the bottom of the pay scale who are at the highest risk.
Transparent communication with employees regarding work expenses helps prevent grievances and legal action.
Tracking All Working Time Including Mandatory Training
Robust logging for remote training and development is necessary. Digital tools can track time spent on modules, ensuring every minute is accounted for in payroll.
Review shift start and end protocols at all sites. Capture preparation time and security delays. These minutes are non-negotiable under UK law.
Advise on historical data reviews to catch errors early. Don’t wait for a government audit. Accumulating errors lead to widespread underpayments and fines.
- Audit training logs
- Review uniform policies
- Check shift prep time
- Monitor net pay thresholds
The Regulatory Future After the Holland & Barrett Minimum Wage Underpayment
The enforcement landscape is shifting rapidly. Historical excuses no longer shield firms from aggressive new oversight bodies. Recent naming rounds serve as a warning for the entire retail sector.
The Impact of the 2026 Fair Work Agency on Enforcement
The Fair Work Agency centralizes labor enforcement from April 2026. This body possesses stronger investigative tools than previous departments. It possesses the power to improve legal compliance across all UK sectors.
Expect higher fines during the transition from HMRC enforcement. Naming rounds will become more frequent. This transparency puts corporate reputations at risk during every audit.
The agency targets systemic payroll failures within retail giants. Large organizations must audit historical practices now. Compliance is a matter of corporate survival in this stricter environment.
Regulators also monitor classification issues, similar to how France launches campaigns to tackle worker misclassification to protect rights.
- Centralized enforcement through a single, powerful regulatory body
- Increased budget of 60.1 million pounds for robust staffing
- Expanded scope covering holiday pay and sick pay by 2027
Adapting to the Upcoming Employment Rights Bill Requirements
The new bill strengthens protections for 15 million workers. It removes age bands for minimum wage calculations. This simplifies payroll but increases costs. Firms must prepare for these 2026 shifts immediately.
Prepare for the 2026 shift in wage thresholds. Age-based discrimination in pay is ending. This requires a total overhaul of many retail pay scales.
Regulators seek systemic errors in corporate payroll practices. Minor technical glitches lead to massive headlines. Proactive auditing remains the only defense.
To Sum Up
The Holland & Barrett minimum wage underpayment highlights how uniform costs and unpaid training create massive payroll liabilities. Businesses must audit all working hours and deductions immediately to ensure compliance before the 2026 Fair Work Agency intensifies enforcement. Proactive remediation secures legal standing and protects your brand’s future reputation.
