Paying cleaners for every minute the minimum wage counts

Greymill AcademyUK6 min readReviewed Oct 202624 primary sourcesUS version

The short answer

Travel between houses, unpaid set-up minutes, uniform deductions and the wrong kind of holiday pay are how cleaning firms underpay without meaning to.

The takeaway. Test each pay period: pay, less job-cost deductions, divided by all working time including travel between jobs, training and set-up. It must not fall below the minimum wage.

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Written for owners of UK cleaning businesses: contract cleaners for offices, schools, healthcare and soft FM subcontracts, domestic cleaning firms, agencies and apps, and specialists in after-builders, end-of-tenancy, window, carpet and biohazard cleaning.

The short version

  1. Add up all working time each pay period.Include travel between jobs, set-up, lock-up and required training. Travel from home to the first job, and home from the last, does not count.
  2. Subtract uniform and kit deductions from pay.Uniform, kit, DBS checks or parking taken from wages reduce pay for the minimum wage test. Mileage payments do not count as pay.
  3. Divide pay by hours and check the rate.Divide pay, after those deductions, by working time. If below the minimum wage for their age, pay for travel time or reprice the work.

When a cleaner is paid at or close to the minimum wage, a few unpaid minutes a day are enough to take them below it. Unpaid set-up or lock-up minutes, unpaid induction or COSHH training, and clock-in times rounded down are the classic arrears in cleaning, along with travel between jobs.

The rule

What counts as working time

For the minimum wage, working time includes time on site, travel between sites or houses during the shift, required training, and time the cleaner is required to be at a site waiting. Travel from home to the first job, and from the last job home, is excluded. As of Oct 2026.

National Minimum Wage Regulations 2015 Part 5, including regs 33 and 34

The test runs for each pay reference period: pay for minimum wage purposes, divided by hours of working time. The National Living Wage is £12.71 an hour at 21 and over from 1 April 2026, £10.85 at 18 to 20, and £8.00 at 16 to 17 and for apprentices. Keep the records for 6 years. As of Oct 2026.

Per-clean pay is where travel bites. Say a domestic cleaner is paid £36 a clean for 4 cleans a day of 2.5 hours each, with 40 minutes' drive between each of them: that is 10 hours on site plus 2 hours of travel.

A domestic cleaner paid £144 for a 12-hour working day (worked, As of Oct 2026)
Arrears: 71p an hour x 12 hours x 230 working days£1,959.60
Penalty on a new notice, at 200% of the arrears£3,919.20
What the underpayment can cost for one cleaner£5,878.80
Effective hourly pay£12

£144 / 12 hours of working time, 71p below £12.71Arrears are repaid at today's rate if higher, and the penalty is subject to the per-person cap and payment conditions. Pay for travel time or reprice the cleans.

The rule

Deductions for uniform, kit and checks

Deductions or payments for the employer's own use and benefit, and for costs connected with the job such as uniform, equipment, a DBS check or site parking, reduce pay for minimum wage purposes. Expense payments such as mileage are not pay. As of Oct 2026.

National Minimum Wage Regulations 2015 regs 10, 12 and 13

AvoidDeducting £15 for a tunic from a new cleaner's first week of 20 hours at £12.71 (£254.20), because it seems fair that they contribute. As of Oct 2026.
Do this insteadSupplying the uniform free, or taking a deduction only where pay stays above the minimum.

Pay for minimum wage purposes falls to £239.20, or £11.96 an hour, so that week is underpaid. As of Oct 2026.

The rule

Holiday pay depends on the hours pattern

Irregular-hours and part-year workers (leave years from 1 April 2024) accrue holiday at 12.07% of hours worked. You may pay them rolled-up holiday pay instead: 12.07% of their normal pay for the period, including regular overtime, commission and shift premia, shown separately on each payslip. For example, 80 hours at £12.71 is £1,016.80, so rolled-up holiday pay is £122.73. Fixed-hours cleaners get 5.6 weeks a year, capped at 28 days, and rolled-up pay is not allowed for them. As of Oct 2026.

Working Time Regulations 1998 regs 13, 13A, 15B and 16A

If you already pay rolled-up holiday to a cleaner on fixed hours, move them to paid leave and take advice on whether the sums already paid discharge the leave they have taken.

Before and around the first shift

  • Right to work: check, and copy, before the first shift. A check done after someone has started gives no statutory excuse, and the civil penalty is up to £45,000 per illegal worker for a first breach. As of Oct 2026.
  • DBS: schools and healthcare clients set the level in the contract. You pay, or any deduction must not take pay below the minimum wage.
  • Sick pay: since 6 April 2026, statutory sick pay runs from the first day of sickness with no lower earnings limit, which brings in many low-hours cleaners. Put the cost of day-one cover in your contract prices. As of Oct 2026.
  • Harassment on client sites: from 30 October 2026, as reported (recheck the commencement date), you must take all reasonable steps to prevent sexual harassment of your cleaners, and you can be liable for harassment by third parties, such as people at a client's site. Set up a reporting route on every client site now. As of Oct 2026.
  • Salaried supervisors still get the minimum wage over their actual hours, call-outs and early unlocks included.
The rule

If HMRC finds arrears

Arrears are repaid at today's rate if higher. New notices from 7 April 2026 come under the Employment Rights Act 2025, with the same penalty as before: normally 200% of each person's arrears, capped at £20,000 per person, with a £100 minimum in total. Paying the arrears and at least half the penalty within 14 days beginning with the notice treats the penalty as paid, and an appeal is normally due within 28 days. As of Oct 2026.

National Minimum Wage Act 1998 s.17; Employment Rights Act 2025 ss.107, 108 and 110(2)

Geofenced clock-in is your best evidence that travel and set-up time were paid. Tell staff what is collected and why, and never track them outside working time.

Asked in Greymill

Example question and answer from Staff & HR
You
Thinking of paying my domestic cleaners £36 a clean, not hourly. All are 21 or over. Typical day: 4 cleans of 2.5 hours, 40 minutes' drive between each. That's £144 for 10 hours, so £14.40 an hour. Fine for minimum wage?
Staff & HR
It fails. Counting the drives, it is £12.00 an hour, 71p below the minimum.

The test, on a typical day:
On site: 4 x 2.5 hours = 10 hours
Driving between houses: 3 drives x 40 minutes = 2 hours
Working time: 12 hours
£144 / 12 = £12.00, against the National Living Wage of £12.71 at 21 and over (As of Oct 2026)

Why the drives count: travel between jobs during the shift is working time. Home to the first house, and the last house home, are left out.

What it can cost per cleaner, over 230 working days:
Arrears: 71p x 12 hours x 230 = £1,959.60
Penalty, normally 200% of the arrears (As of Oct 2026): £3,919.20
In all: £5,878.80

Pay for the travel time or reprice the cleans. Send me a typical week and I will work out a per-clean rate that passes.

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Your question

I run a cleaning business in the UK. My cleaners are paid [rate per hour or per clean], and a typical day is [number of jobs, hours on each, and travel time between them]. We [do or do not] deduct for uniform, DBS checks or anything else. [Number] are on fixed hours and [number] on irregular hours, and we pay holiday as [paid leave or rolled-up pay]. Check each pattern against the minimum wage for a pay period, show me any shortfall, and tell me what to change.

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Sources

The primary sources behind this lesson, checked Oct 2026.

  1. Current rates; lib-statutory-uk.js wages (People and pay: hourly minimum wage, holiday and the new law)
  2. reg 34 (travelling treated as time work; home to first site and last site home excluded), reg 33 (training treated as time work) (People and pay: hourly minimum wage, holiday and the new law)
  3. regs 10, 12, 13 (People and pay: hourly minimum wage, holiday and the new law)
  4. regs 6, 59 (People and pay: hourly minimum wage, holiday and the new law)
  5. Modern Slavery Act 2015 s.54; FWA launch per lib-statutory-uk.js fairWorkAgencyFrom (People and pay: hourly minimum wage, holiday and the new law)
  6. regs 15B, 16A (People and pay: hourly minimum wage, holiday and the new law)
  7. Uber [2021] UKSC 5; Autoclenz [2011] UKSC 41 (Hard cases: pay, tax, domestic and site)
  8. regs 30(b), 36, 39(1) (Hard cases: pay, tax, domestic and site)
  9. reg 16A (Hard cases: pay, tax, domestic and site)
  10. regs 4(2), 9(b) (Hard cases: pay, tax, domestic and site)
  11. WAHR 2005; RIDDOR reg 4 (Hard cases: pay, tax, domestic and site)
  12. Civil penalties (Hard cases: pay, tax, domestic and site)
  13. Rynda (UK) Ltd v Rhijnsburger [2015] EWCA Civ 75 (Pitfalls that embarrass the product)
  14. reg 18 (Pitfalls that embarrass the product)
  15. reg 2 (definition of work at height) (Pitfalls that embarrass the product)
  16. s.3 (Pitfalls that embarrass the product)
  17. Gangmasters Licensing (Exclusions) Regulations 2013 Sch Part 1 para 3 (Pitfalls that embarrass the product)
  18. reg 35 (Operations and software)
  19. reg 11(6) (Who must sign off: time-critical steps first)
  20. reg 13(4) (Who must sign off: time-critical steps first)
  21. www.legislation.gov.uk (Who must sign off: time-critical steps first)
  22. s.51 (Who must sign off: time-critical steps first)
  23. s.15 (Who must sign off: time-critical steps first)
  24. regs 10 and 13 (Who must sign off: time-critical steps first)

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