Mandatory training time : calculate what you are owed

• Acas defines mandatory training as any training your employer says you need to do.
• Whether you get your normal contractual pay for that time depends on what your contract / written statement says, especially if training sits outside normal working hours.
• For National Minimum Wage, time receiving training required by the employer is treated as working time (HMRC NMWM08500; Regulations on hours spent training).
• Associated travel between work and an approved training venue can also count; ordinary home-to-training commuting generally does not (GOV.UK / HMRC).
• Deductions for training costs are only lawful if the contract allows them, and they must not pull pay below NMW.
• From April 2026, workers aged 21 and over get at least £12.71 an hour on hours that count for NMW.
• Tribunal pay claims: today usually 3 months minus 1 day; from 1 October 2026, most claims become 6 months minus 1 day if the clock starts on or after that date (Acas).

Acas says mandatory training is any training your employer says you need to do. Pay for the time spent on it depends on what your contract says. If you have employee or worker status and started after 6 April 2020, mandatory training must appear in your written statement of employment particulars.

Mandatory training is often at the workplace during normal hours. If it is not during normal working hours, Acas says check the written statement to see whether you will be paid for the training time, and talk to your manager if you are unsure.

Separately, Acas is clear for workers on or near the minimum wage: the employer should pay you for time spent on mandatory training, and any deduction for training costs (course fees, travel costs) must not take pay below the minimum wage. Those deductions also need a contractual basis.

Treat that as two layers: the contract / written statement (what rate applies, including evenings), and the NMW floor (employer-required training hours still feed the average so you cannot sit under the legal rate).

HMRC NMWM08500 (unmeasured work: training time) states that for a worker performing unmeasured work, time receiving training required by the employer is treated as working time. The important factor is whether the worker must undertake the training under the contract. Whether the employer already paid for the course fees is indicative but not decisive. Where it is unclear, HMRC says the deciding factor should be whether the training is wholly or mainly in connection with the work and whether it is "approved" in some manner by the employer.

GOV.UK's calculating guidance lists time spent training among the hours that count for salaried hours work, time work, output work and unmeasured work. For salaried hours work it also lists training or travelling from a workplace to training. Hours of training that are not required by the employer and do not take place when the worker would otherwise be working are in the "does not count" list for salaried hours work.

Regulation 19 of the National Minimum Wage Regulations 2015 defines hours spent training as including:

• attending somewhere other than the normal workplace, when the worker would otherwise be working, for employer-approved training;
• travelling, when the worker would otherwise be working, between a place of work and that training;
• receiving such training at the normal place of work.

"Would otherwise be working" includes situations where hours vary so it is uncertain whether the worker would otherwise be working.

In plain terms: if your employer requires the module, induction, or refresher, treat those hours as candidates for the NMW calculation. Optional self-study that nobody required is a different story.

NMWM08500 points to NMWM08490: where training is outside the normal workplace, consider not only attendance time but associated travelling. GOV.UK says travel from work to training venues can count for NMW, while travel between home and the training venue generally does not.

So a common pattern is:

• finish a morning shift, travel from the workplace to a college site for a required course in the afternoon: travel and attendance can count;
• leave home on a day off solely to attend the same course: the home-to-venue leg is usually outside NMW hours, but the training attendance itself may still count if employer-required.

Log both the training clock time and the travel legs with start/end points so you can apply the right rule to each segment.

Acas: employers might want to deduct mandatory training costs (for example course fees). They can only do so if the contract says they can. Any such deduction must not bring pay below the minimum wage.

That interacts with the wider deductions rules under the Employment Rights Act 1996 (authorised deductions) and with NMW pay reductions. A clawback when you leave within six months is a frequent contract term. Even where the contract authorises it, run the NMW test on the pay reference period after the deduction. If the deduction is for the employer's own use and benefit in a way the Regulations strip out of NMW pay, the average can fall under the floor even when the headline hourly rate looked fine.

Keep the paperwork: the clause that authorises the deduction, the amount taken, the hours in that period (including training hours), and the age-band rate.

Example A: unpaid evening e-learning

You are 29. Legal rate from April 2026: £12.71. You work 35 paid hours in a week at £12.71 = £444.85. Your employer also requires 3 hours of online mandatory training outside rostered shifts and pays nothing for those hours.

If those 3 hours count for NMW:

• total counting hours: 38
• pay still £444.85
• average: £444.85 ÷ 38 ≈ £11.71 an hour

Under the floor. Gross top-up to clear NMW: 38 x £12.71 = £482.98, shortfall £38.13 for that week. Four similar weeks ≈ £152.52.

Example B: weekend classroom course plus work-linked travel

Same worker. On Saturday you are required to attend a full-day course (7 hours tuition). The employer also requires you to collect kit from the workplace, travel to the venue, and return the kit: 1 hour each way of work-linked travel that is not a simple home commute.

Counting training and associated travel: 7 + 1 + 1 = 9 hours. If those hours are unpaid, add them into the pay reference period that covers the Saturday and re-test the average against £12.71.

Illustrative floor for those 9 hours alone if no other pay covers them in the period: 9 x £12.71 = £114.39.

Example C: training fee deduction near the floor

You earn £12.80 an hour for 160 hours: £2,048 gross. A £120 mandatory certificate deduction leaves £1,928, or £12.05 an hour if treated as reducing NMW pay: under £12.71. Run the GOV.UK calculator and get advice before accepting that the clawback "must be fine".

Watch for unpaid induction weeks when you are already a worker, mandatory e-learning with unpaid overruns, "do it in quiet moments" that never appear on the payslip, and optional-sounding courses that become mandatory in practice. HMRC's required / approved / connected-with-the-work framing beats the marketing title of the course.

1. List every module the employer said you must complete, with dates and duration.
2. Check the written statement and contract for training pay and any fee clawback clause.
3. Add employer-required training hours (and qualifying associated travel) into the pay reference period.
4. Test the average against the correct age rate (£12.71 for most aged 21+ from April 2026).
5. Raise underpayment in writing. For NMW shortfalls, Acas says choose either HMRC or tribunal for the same underpayment.
6. Watch limitation: 3 months minus 1 day now for most pay claims; 6 months minus 1 day if the clock starts on or after 1 October 2026 (Acas). Early Conciliation can pause the clock; a grievance does not.

• Assuming unpaid evenings are automatically lawful because "everyone does e-learning at home". Employer-required training feeds NMW hours.
• Confusing course fee reimbursement with pay for time. Paying the college invoice is not the same as paying you for the hours.
• Deducting fees without a contract clause, or deducting so hard you go under NMW. Acas flags both problems.
• Ignoring travel from workplace to training. HMRC and GOV.UK treat associated travel as relevant.
• Missing the written statement duty (post-6 April 2020 starters) to include mandatory training particulars.

Training hours disappear from memory faster than shifts. Paye Mes Heures can help you log mandatory modules, associated travel and payslip gaps so an email to HR or Acas starts with a figure, not a vague complaint. It prepares evidence; it does not replace Acas, HMRC, legal advice or a tribunal.

If the employer requires the course, count the time. Check the contract for pay and clawbacks, then protect the £12.71 floor.

• Acas - Getting paid for mandatory training: https://www.acas.org.uk/getting-paid-for-mandatory-training
• HMRC National Minimum Wage Manual NMWM08500 (training time): https://www.gov.uk/hmrc-internal-manuals/national-minimum-wage-manual/nmwm08500
• GOV.UK - Calculating the minimum wage: https://www.gov.uk/guidance/calculating-the-minimum-wage
• GOV.UK - Working hours for which the minimum wage must be paid: https://www.gov.uk/guidance/calculating-the-minimum-wage/working-hours-for-which-the-minimum-wage-must-be-paid
• National Minimum Wage Regulations 2015 (contents): https://www.legislation.gov.uk/uksi/2015/621/contents
• National Minimum Wage Regulations 2015, regulation 19 (hours spent training): https://www.legislation.gov.uk/uksi/2015/621/regulation/19
• GOV.UK - National Minimum Wage and National Living Wage rates: https://www.gov.uk/national-minimum-wage-rates
• Acas - Employment tribunal time limits: https://www.acas.org.uk/employment-tribunal-time-limits