What the latest National Minimum Wage naming round means for construction supply chain due diligence – September 2026

On 3 September 2026, the government¹ named nearly 660 employers who failed to pay the National Minimum Wage, where the announcement then gained traction in the wider press². As of September 2026, around £4 million has been returned to over 27,000 workers, with £7 million in penalties issued to the businesses responsible. 

For construction buyers and main contractors, the immediate question is whether any of those employers operate within their supply chains. 

Inclusion on the list does not necessarily mean an employer deliberately exploited its workforce: underpayments can result from errors involving travel time, deductions, working hours or rate changes. Nevertheless, a supplier’s breach can create reputational, procurement and project-delivery risks for the organisations that rely on it. If you buy, contract, or procure in construction, this naming round matters to you. Not because every named employer is a bad actor, but because minimum wage breaches – whether accidental or deliberate – can quickly become your reputational, tender, and project risk. 

By the end of this post, you’ll understand: 

• What happened in the latest National Minimum Wage naming round 
• Why construction is exposed, when it’s already so volatile from external factors resulting in insolvencies³ 
• How to move from reactive checks to proactive supply chain visibility 

 

What happened in the latest National Minimum Wage naming round? 

The government’s naming round is particularly significant as it is the first naming round since the Fair Work Agency launched in April 2026⁴. Created under the Employment Rights Act, it brings workers’ rights enforcement under one roof for the first time, where it’s set to expand into holiday pay and sick pay too. HMRC continues to enforce the national minimum wage on the agency’s behalf. 

Furthermore, the government has committed to publishing naming lists more regularly. That means more frequent public exposure, and less time between a breach and it becoming public knowledge. 

Construction names appear on these lists 

This isn’t a distant retail or hospitality story. Recent rounds have featured scaffolding firms, surfacing contractors, brickwork and joinery businesses, plumbing and electrical contractors, and facilities and support services. These are the trades main contractors rely on every day. 

 

Accidental or deliberate? 

Before talking about risk, it’s important to be fair to the businesses on these lists. Not every named employer set out to short-change workers. 

Many breaches happen by accident, through the sheer complexity of getting pay right: 

• Unpaid travel time between sites or assignments. 
• Deductions for tools, uniforms, or PPE that quietly push pay below the legal minimum. 
• Missed rate increases when the rates change each April (worth noting with the new April 2026 rates now in force). 
• Misclassified hours, training time, or on-call arrangements. 
• Simple misunderstanding of technical rules around piece work or sleep-in shifts. 

Other breaches are deliberate: employers cutting corners to lower costs and win work on price. 

Here’s the important part: the intent behind a breach shouldn’t paint every named business the same colour. A genuine payroll error is not the same as calculated exploitation. But buyers can’t ignore that the consequences and risk to you are similar either way. An error can still result in arrears, penalties and public naming, although the circumstances and the employer’s response remain relevant. 

The goal isn’t to assume the worst of every supplier. It’s to know where the risk sits, understand the context, and make informed decisions.

 

Why this hits construction harder than most sectors 

Construction carries a structural challenge that few other industries face: layered subcontracting. 

Multiple tiers hide the risk 

A single construction project can involve several tiers of subcontractors and labour agencies. That makes it genuinely hard to see who is actually paying workers, and whether they’re paying correctly. Risk can sit two or three tiers down and still land on your reputation. 

That’s not a criticism of subcontractors: it’s the reality of how construction delivery works. But it means labour compliance is harder to see and easier to inherit. 

The pressures that lead to breaches 

Tight margins, fast mobilisation, and fluctuating labour demand all increase the chance of payroll slip-ups. A subcontractor scaling up quickly for your project may make an honest mistake with travel time or deductions and you may never know until a list is published. 

 

The real risks for construction buyers and main contractors 

When a supplier is named, the fallout rarely stays contained. Some of the things at stake for businesses that buy from them include: 

Tender and framework exposure 

Public-sector contracting authorities must consider the exclusion grounds set out in the Procurement Act. Certain serious minimum wage offences can be relevant, including the offence of refusing or wilfully neglecting to pay the minimum wage. However, appearance on a naming list does not by itself mean that a supplier must be excluded: authorities must consider the applicable ground, whether the circumstances are continuing or likely to recur, and evidence of remedial action. 

Naming alone does not automatically trigger exclusion. Serious minimum-wage offences may engage exclusion grounds, and authorities must consider the facts, recurrence and remedial action. 

Reputational damage 

Your brand can be tarnished by a supplier’s conduct, regardless of your direct involvement. Public naming is designed to stick and it spreads through press and social channels quickly. 

ESG and social value credibility 

Social value commitments mean little if labour standards fail within your chain. Your ESG position is only ever as strong as your weakest supplier link. 

Project continuity 

A subcontractor facing significant fines and arrears may become financially unstable. That can mean delays, mid-project replacements, and disruption you didn’t budget for. 

Due diligence scrutiny 

A named supplier raises hard questions from clients, investors, and regulators about your oversight, and whether your risk processes are fit for purpose.

 

Why reactive due diligence no longer cuts it 

Most supply chain checks still happen at a single point in time, usually at onboarding. That’s no longer enough. 

Point-in-time checks miss ongoing risk 

A supplier who’s fully compliant when you onboard them can appear on a naming list months later. Annual reviews leave long, dangerous blind spots. 

Manual monitoring doesn’t scale 

Tracking hundreds of subcontractors across multiple live projects by hand is unrealistic. By the time you spot a problem in the press, the damage is already done. 

The shift buyers need to make 

With naming rounds becoming more frequent and the Fair Work Agency ramping up, the smart move is clear: shift from periodic, reactive checking to continuous, proactive visibility. 

 

Reactive to proactive: how Risk Radar helps you stay ahead of supplier risk 

This is exactly the gap our Risk Radar tool is designed to address, giving you early, reliable visibility into your supply chain before issues escalate: 

• Prompt visibility of named suppliers: Check your supply chain against the government’s official National Minimum Wage naming data, helping you identify relevant enforcement findings without manually reviewing lengthy publications. 
• Regularly refreshed data: The National Minimum Wage dataset is checked and refreshed weekly, helping your team act promptly when new official information becomes available. 
• A broader view of supplier risk: Consider minimum wage findings alongside sanctions, politically exposed persons, adverse media, tax defaults, CMA investigations and construction court data. 
• Faster, more informed decisions: Use clear dashboards to investigate flags, document your assessment and support your case for stronger tender submissions. 

The value isn’t in blacklisting businesses. It’s in knowing what’s there, understanding the full picture, and acting early, before a supplier ends up on the next list.

 

Next steps: protect your projects and reputation with Risk Radar 

The latest naming round is a reminder that labour compliance failures don’t stay with the employer who made them. In construction, where subcontracting runs deep, they ripple outward into your tenders, your brand, and your project delivery. 

Well-managed construction businesses aren’t the ones who react fastest after a supplier is named. They’re the ones who spot the exposure and treat every supplier fairly by understanding the full context of any flag. 

Request a Risk Radar demo to see how you can identify supplier financial risk and more before it affects your projects and brand reputation. 

 

Key takeaways 

• Enforcement is becoming more frequent and more visible, and construction suppliers are on the lists. 
• Breaches happen both accidentally and deliberately. The intent varies, but the risk to buyers is real either way. 
• A supplier breach can quickly become your tender, reputation, ESG, and continuity risk. 
• Reactive, manual due diligence leaves gaps that continuous monitoring closes.