Strengthen Statutory Sick Pay
See Statutory Sick Pay for more details.
National Minimum Wage
Outside of the ERA 2025, the Government has promised to deliver a genuine living wage that accounts for the cost of living. It has changed the Low Pay Commission’s remit to factor in the cost of living when recommending minimum wage rates. It has also instructed the Low Pay Commission to narrow the gap between the minimum wage rate for 18-20 year-olds and the National Living Wage as a first step towards achieving a single adult rate.
As a result, the following changes to hourly rates were applicable from 1 April 2025:
- National Living Wage (21 and older): increased from £11.44 to £12.21
- National Minimum Wage (18 to 20-year-olds): increased from £8.60 to £10.00
- National Minimum Wage (16-17 year olds and apprentices): increased from £6.40 to £7.55
- Daily accommodation offset increased from £9.99 to £10.66.
The Government has announced that the National Minimum Wage hourly rates will increase again from 1 April 2026 as follows:
- National Living Wage (21 and older): from £12.21 to £12.71
- National Minimum Wage (18 to 20 year olds): from £10.00 to £10.85
- National Minimum Wage (16-17 year olds and apprentices): from £7.55 to £8.00
Tax and National Insurance Contributions (‘NICs’)
Key changes in the 2024 Autumn Budget (on 30 October 2024) included:
- Income Tax and NIC personal allowance thresholds frozen until the 2028 deadline set by the Conservative Government.
- From April 2025, the rate of employer NICs was increased by 1.2 percentage points, from 13.8% to 15%.
- The Secondary Threshold – the per-employee threshold at which employers become liable to pay NICs on each employee’s salary was reduced from £9,100 per year to £5,000 per year from April 2025 until April 2028 and then will increase by CPI thereafter.
- The Employment Allowance also increased from £5,000 in April 2025 to £10,500 and is extended to all eligible employers by removing the £100,000 threshold for eligibility. Meaning that 865,000 employers will pay no NICs from this year.
The Autumn Budget on 26 November 2025 did not increase headline rates of taxes to income tax, NICs or Value Added Tax. However, some headline changes include that:
- The Government will maintain the freeze to income tax thresholds and the equivalent NICs thresholds for employees and self-employed individuals at their current levels for a further three years from April 2028 to April 2031.
- The Government will also maintain the current NICs secondary threshold for employer contributions from April 2028 to April 2031.
- From April 2029, only the first £2,000 of pension contributions made by an employee each year through a salary sacrifice scheme will be exempt from NICs, where currently there is not a cap. Employer and employee NICs (but not income tax) will be charged in the usual way on salary sacrificed pension contributions above the £2,000 annual cap.
Internships and Apprenticeships
The Government has indicated it wants to ban unpaid internships, except when they are part of an education or training course. The Government launched a call for evidence on 17 July 2025, which considers unpaid internships and internships paid below the National Minimum Wage, unpaid work trials, voluntary work, volunteers and work shadowing. A response to this consultation was published on 27 February 2026, which summarises the findings which will help inform the Government’s next steps. In respect of unpaid internships, the Government has said it will 1) review and expand Government guidance; 2) use existing enforcement channels and the new Fair Work Agency to enforce non-compliance; and 3) bolster existing communications campaigns to help young people understand their rights.
The Government has announced it wants to make changes to the funding of apprenticeships in England. As part of the Autumn Budget 2025, The Government announced that it will provide a £1.5 billion investment over the next three years in employment and skills support. This includes providing £820 million worth of investment to fund a new Youth Guarantee (read our article here for more) and £725 million for the Growth and Skills Levy to help support apprenticeships for young people, including a change to fully fund SME apprenticeships for eligible people under 25.
In a written statement in December 2025, the Government outlined what the Youth Guarantee would comprise, including:
- A new Youth Guarantee Gateway to be introduced for young people on Universal Credit who are looking for work. Eligible individuals would be offered a dedicated session followed by four weeks of additional intensive support with a Work Coach
- New Youth Hubs to be established in over 360 locations to help young people access opportunities
- Creation of up to 150,000 additional work experience placements and up to 145,000 additional bespoke training opportunities designed in partnership with employers (‘Sector-based Work Academy Programmes’) with guaranteed job interviews
- Fully funded apprenticeship training costs to eligible 16-24 year olds by removing the need for non-levy paying employers to co-fund
- Expansion of foundation apprenticeships into sectors such as hospitality and retail
- A Jobs Guarantee scheme to provide six months of paid employment for long-term unemployed 18-21 year olds on Universal Credit
Tipping
New laws on tipping were introduced in October 2024, which regulate how employers allocate tips, gratuities and service charges among workers and eligible agency workers (see here for an article we wrote at the time). As part of this, employers are required to introduce a written tips policy where qualifying tips, gratuities, and service charges are paid on more than an occasional and exceptional basis.
The ERA 2025 strengthens this by requiring employers to consult with either recognised trade union representatives or workers’ representatives or (where there are no representatives) workers directly affected by the policy before preparing a first draft tipping policy and when reviewing such policy. Any tips policy must also be reviewed every three years from first implementation. Employers will also be required to make an anonymised summary of the views expressed in the consultation available to all workers of the employer at the place of business where the tips policy applies.
A consultation was launched on 5 February 2026 seeking views on the new consultation requirements and review of tipping policies, including the steps that should be taken when consulting and any potential challenges that employers will face in consulting with workers. The consultation also requests feedback on the statutory Code of Practice on fair and transparent distribution of tips.
Timing and developments
Statutory sick pay
The Government has said that this measure will take effect in April 2026.
Minimum wage
Rates increased on 1 April 2025 and will increase again on 1 April 2026.
Tax and NICs
Timings vary see above.
Unpaid internships and apprenticeships
Call for evidence launched on 17 July 2025 and closed on 9 October 2025 and its response was published on 27 February 2026.
Tipping
Included in the ERA 2025. A consultation was launched on 5 February 2026, which will be open until 1 April 2026. The Government’s updated timeline indicates that measures in respect of tipping will take effect in October 2026.
Sources
Announcement on 30 July 2024 and call for evidence, Skills England Report, SSP Consultation on 21 October 2024, Response to SSP consultation 4 March 2025, Autumn Budget 2025, Government Factsheet: Tips and gratuities, Government Business Guidance on National Minimum Wage, Consultation on strengthening the law of tipping, Making Work Pay: call for evidence on unpaid internships government response.