What this guidebook covers
Illegal-working penalties tripled in February 2024, to up to £60,000 per worker for a repeat breach, and car washes are a named target: the Home Office made 808 visits to car washes in 2025. HMRC names employers who underpay the minimum wage, car dealers among them.
This guidebook covers 6 employment standards with 18 checkpoints across sales, workshop, valeting, car wash and apprentices: right-to-work checks before day one, follow-up checks, valeting and car wash contractors, minimum wage after deductions, apprentice pay, and working hours and holiday pay.
The 6 employment standards
| Code | Standard | Ideal fix time |
|---|---|---|
| EMP-01 | Right to work checks before day one | Immediate |
| EMP-02 | Follow-up checks | 7 days |
| EMP-03 | Valeting and car wash contractors | 30 days |
| EMP-04 | Minimum wage after deductions | 72 hours |
| EMP-05 | Apprentices paid correctly | 72 hours |
| EMP-06 | Working hours and holiday pay | 30 days |
How to run a UK right to work and minimum wage audit, step by step
- Confirm what applies. Include contracted valeting and car wash crews as well as your own staff; the Employment Rights Act 2025 is bringing further changes in stages.
- Walk the site, standard by standard. Score each of the 18 checkpoints Pass, Fail or N/A. N/A only where the standard rules it out, with the reason recorded. Check right-to-work copies against start dates, and recalculate pay after deductions for uniforms and tools.
- Capture the evidence. A pass counts only with proof captured at the time of the audit: right-to-work copies with check dates, payslips, contractor agreements and holiday records.
- Give every fail an owner and a fix time. Record what you saw and who owns the fix. Each standard carries an ideal fix time, from immediate to 30 days, counted from audit submission (see the table above).
- Fix it, then prove it. The site fixes the cause and uploads proof of closure; the auditor checks the proof before closing the finding.
- Re-check at the next audit. Confirm closed findings stay closed, and look for the same fail at your other sites so one gap doesn't repeat across the network.
Who this guidebook is for
- Dealer principals
- HR and payroll managers
- Auditors
A reference document, not legal advice. Fines and rules change: check the current text with the regulator or your legal adviser before acting.
