Decide which hours count before looking at the payslip
HMRC's training-time guidance says training required by the employer is working time for a worker doing time work, including when it takes place outside the normal shift. Where the arrangement is less clear, HMRC looks at whether the learning is mainly connected with the job and approved by the employer. Required induction, supervised shadow shifts, refresher courses and compulsory online modules should therefore be captured, even when a rota has no client visit against them. Check the worker's type of work before applying a formula; salaried-hours arrangements have their own rules.
The government's working-hours guidance also covers travel from a workplace to training. Ordinary travel between home and work generally does not count in the minimum-wage calculation. Record where training happened and whether travel was required rather than treating every journey alike. A voluntary course unrelated to the job needs a separate assessment; a label in the learning system does not settle whether the employer required it.
Give every session a route into payroll
Use one register for new starters and existing staff. For each session, record the worker ID, course or shadow shift, whether it was required, actual start and finish times, unpaid breaks, location, manager approval, completion evidence and pay period. Keep a correction field for a session entered after payroll cut-off. A certificate proves completion, but it rarely proves how many hours were spent, particularly for online learning completed in stages.
Match that register to the rota and payroll import by worker ID and date. Mark a training hour already included in a paid shift so it is not counted twice. Keep a separate line for required learning done at home or between visits, because those are the hours a visit-only export can miss. LOYALS supports London and UK care providers with payroll and the worker-level checks behind it; the schedule should allow someone else to rebuild the same pay-period total from source records.
| Source | What to check | Payroll result |
|---|---|---|
| Learning record | Actual date and duration | Add missing required hours |
| Shadowing rota | Attendance and paid shift | Count once, not twice |
| Pay run | Eligible pay and period | Test the hourly average |
| Late correction | Original period and payment date | Escalate before filing |
Work through an illustrative weekly pay period
Assume a carer aged 21 or over works 30 paid care hours at a contractual £14 an hour and completes five hours of required induction in the same week. The care pay is £420. If the induction is omitted, the minimum-wage test spreads £420 over 35 working hours, giving £12 an hour. The published rate from 1 April 2026 is £12.71 for a worker aged 21 or over, so this illustrative period has a minimum-wage shortfall of £24.85. That is the statutory gap in this example, not necessarily the whole contractual pay owed for the five training hours.
If the contract pays those five hours at £14, adding £70 brings total pay to £490 and the average to £14 across 35 hours. Check the contract and any agreed training rate as well as the statutory floor. A higher rate on ordinary shifts does not remove the need to count required training. The government's calculation guidance requires the average to be tested in each pay reference period, which cannot be longer than 31 days; surplus pay in another period does not replace this check.
| Illustrative weekly check | Training omitted | Training paid at £14 |
|---|---|---|
| Care and training hours | 30 + 5 = 35 | 30 + 5 = 35 |
| Total pay | £420 | £490 |
| Average per hour | £12.00 | £14.00 |
| Against £12.71 floor | £24.85 short | Above floor |
Check training costs and awkward start dates
A charge or repayment for required training can reduce the pay that counts for minimum-wage purposes. HMRC's training-cost guidance distinguishes a course required for the job from a worker's separate course that the employer pays for on their behalf. Do not assume every deduction has the same effect. Record who required the course, who paid the provider, the contract term, the deduction and the period in which it was made, then seek a specific review if the position is unclear.
For induction before a formal start date, establish when the worker's contract was formed and whether the activity was work or genuinely part of selection. HMRC flags this distinction in the same guidance. Do not mark a shadow shift unpaid simply because the first payslip has not yet been issued. A manager should resolve start-date exceptions before the payroll cut-off, with the decision and underlying documents retained.
Approve the pay run with an exception list
Reconcile the training register, rota and draft payroll by worker and period. Check missing sessions, duplicate hours, late learning entries, the age or apprentice rate that applies, and any training-related deduction. Use pay that actually counts for the statutory test, rather than gross payroll or a headline contractual rate. The employer guidance says records must prove compliance and be kept for at least six years under the current rule. Keep the period calculation, source hours, correction approval and final payslip together.
Hold any unresolved statutory shortfall for review before filing. Where a past period is affected, calculate arrears using the correct rate and dates rather than netting the difference against a later surplus. The existing HMRC care-agency check guide explains the wider enquiry and record request; this page is the narrower control that helps prevent a training-hours omission in the first place. For visiting care, run the separate rota and travel-time reconciliation alongside it.