Know your holiday-pay number before an inspector does.£295 fixed. Five working days.
The Fair Work Agency expects to start enforcing holiday pay during 2027, reaching back to 18 December 2025, with a proposed penalty of 200% of what was underpaid. A chartered accountant recomputes a sample of your staff and gives you the range, in writing.
- Snapshot £295.
- Full audit £2,950, with the snapshot credited.
- Monitoring £395 a month.
- No VAT is added: the firm is not VAT registered. No other charges.
- Prices checked on 1 November 2026.
18 December 2025
The earliest date the agency can reach back to, under the government's 2026 consultation. A six-year limit is proposed, so the window grows each year.
6 years
How long holiday records must be kept under regulation 16B, a duty in force since 6 April 2026.
200%, proposed
Penalty on the underpayment in the consultation, capped at £20,000 per worker. Not yet law at 1 November 2026.
Who should get the snapshot
- Care providers with hourly and bank staff (named by the agency as high-risk).
- Construction and civils firms with weekly-paid operatives on overtime (also named).
- Security, cleaning and facilities firms with variable rotas.
- Recruitment agencies running their own payroll for temps.
- Schools and trusts with term-time-only staff.
- Anyone whose payroll pays all holiday at basic rate.
What you receive
- The sample: which workers, which weeks, which method applied to each.
- The recomputation, worker by worker, against what was paid.
- The exposure as a range from 18 December 2025, and the proposed six-year ceiling.
- The three errors driving it, in plain words, with the fix for each.
- A one-page note for your board or payroll provider.
It is the arithmetic, done on a sample, by someone whose name goes on it. It is not a legal opinion and not an agency finding.
Three prices
Start with the snapshot. Most employers stop there, or go on to the audit with the snapshot fee credited.
Exposure snapshot
£295
Fixed. Five working days from receiving your exports.
- A sample of your irregular-hours and part-year staff recomputed on the 52-week basis
- Your exposure from 18 December 2025, as a range, with the proposed six-year ceiling shown separately
- The three errors most likely to be driving it
- A written note you can show your board or your payroll provider
Full exposure audit
£2,950
Fixed. Snapshot fee credited. Three to four weeks.
- Every affected worker recomputed across the period that matters
- A correction schedule, worker by worker
- The records pack an inspector would ask for
- A call with Patrick to walk through it
Forward monitoring
£395
Per month. No minimum term.
- Each pay run checked before it goes
- Reference-period calculations kept current
- A quarterly statement that the records are in order
- Someone to ask when a contract changes
Common questions
What is changing, and when?
The Fair Work Agency opened on 7 April 2026. Its delivery plan (published 21 August 2026, updated 16 October 2026) says it will be ready for its holiday-pay remit from April 2027 and expects enforcement to begin during 2027. The government consulted between 30 June and 22 September 2026 on how it will enforce; the consultation says the agency cannot enforce underpayments from before 18 December 2025.
How far back can it go?
To 18 December 2025, under the consultation. A six-year limit is proposed, so the window grows a year at a time and reaches six full years around December 2031. Workers can still bring their own tribunal claims, which face a two-year backstop for unlawful deductions. Pages that say "six years back from April 2027" are describing the ceiling, not what the agency can reach next year.
What are the penalties?
Proposed, not yet law at 1 November 2026: 200% of the arrears, capped at £20,000 per worker, with a £100 minimum per case, and the penalty treated as paid if all the arrears plus half the penalty are paid within 14 days. The agency has said it will name employers. The government had not published its response to the consultation when this page was checked.
Why would we be exposed?
Because paying every type of holiday at basic rate is common, and for staff with overtime, commission, irregular hours or part-year contracts the law requires the 52-week average or, since April 2024 for irregular-hours and part-year workers, the 12.07% method. The difference is small per week and large across a workforce and a period of years.
Which employers does the agency say it is looking at?
Its delivery plan names social care and construction as high-risk sectors. Security, cleaning, recruitment, hospitality and schools with term-time staff carry the same calculation, though the agency has not named them.
What records must we keep?
Since 6 April 2026, regulation 16B of the Working Time Regulations requires records showing holiday entitlement and pay, kept for six years. Acas says failing to keep them could be a criminal offence. The snapshot tells you whether yours would stand up.
What do you need from us?
Payroll exports for the period, rota or timesheet data, and the leave records. Spreadsheets are fine. Nothing goes into public AI tools and the data is held under a written engagement letter.
Is this legal work?
No. It is a calculation and a records exercise, which is accountancy work, and the snapshot is not an agency finding of any kind. If it shows a dispute that needs an employment lawyer, we say so and you choose one.
Get the snapshot
Your name and number. Patrick calls to agree the fee in writing and tell you which exports to send. The snapshot is in your inbox five working days after they arrive.
Useful to have ready
- A payroll export covering at least the last 52 weeks.
- Rota, timesheet or hours data for the same period.
- Leave records and the holiday clause from your contracts.
- Headcount by contract type: salaried, hourly, zero-hours, term-time.
Read first
The rules as they stand on the date shown, with the sources, so your board can check them.
- How far back can the Fair Work Agency claim holiday pay?
- The proposed penalty, worked for 10, 25 and 50 workers
- What holiday records a care provider must keep from April 2026
- What a holiday-pay audit costs in the UK
- All holiday-pay guides
Sources for this page
- GOV.UK: Make Work Pay: holiday pay compliance and enforcement (consultation, 30 June to 22 September 2026; proposed penalty terms; underpayments before 18 December 2025 cannot be enforced by the agency).
https://www.gov.uk/government/consultations/make-work-pay-holiday-pay-compliance-and-enforcement - GOV.UK: Fair Work Agency delivery plan for 2026 to 2027 (holiday-pay enforcement expected to begin in 2027; social care and construction named as high-risk).
https://www.gov.uk/government/publications/fair-work-agency-delivery-plan-for-2026-to-2027 - business.gov.uk: Fair Work Agency: enforcement of statutory holiday pay will start in 2027.
https://www.business.gov.uk/campaign/employment-changes/employers/fair-work-agency/ - Acas: Keeping holiday records (at least six years; failing to keep them could be a criminal offence).
https://www.acas.org.uk/checking-holiday-entitlement/keeping-records - GOV.UK: Holiday pay and entitlement reforms from 1 January 2024 (52-week reference period; 12.07% for irregular-hours and part-year workers).
https://www.gov.uk/government/publications/simplifying-holiday-entitlement-and-holiday-pay-calculations/holiday-pay-and-entitlement-reforms-from-1-january-2024