NHS Strike Starts April 7. So Does the Fair Work Agency. Here's What Care Homes Must Do Now.

On 7 April 2026, two things happen at exactly the same time — and most care home managers don't know about either of them.

NHS resident doctors begin a six-day walkout. And the Fair Work Agency formally launches, with walk-in enforcement powers covering the National Minimum Wage, Statutory Sick Pay, and holiday pay — starting immediately, with care homes as a primary target.

If you run a care home, supported living service, domiciliary care agency, or any healthcare setting that uses agency staff, you are in the crosshairs of both events at once. The window to prepare is 8 days.

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What's Happening on April 7

The NHS Resident Doctors Strike (7–13 April)

The British Medical Association has confirmed a sixth-day walkout starting at 7am on Tuesday 7 April, running until 6:59am on Monday 13 April. This is the 15th round of industrial action by resident doctors since 2023.

What this means for care settings:

• GP surgeries and community services will face reduced referral capacity
• Hospital discharge backlogs will slow — residents staying longer, increasing pressure on care home beds
• Agency staff demand surges across the sector as NHS trusts redeploy staff and care providers scramble to maintain cover
• Higher agency rates — during previous NHS strikes, agency nursing rates increased by 15–30%

The Fair Work Agency Goes Live — Same Day

The Fair Work Agency (FWA) is the UK's new employment enforcement body, taking over from HMRC's National Minimum Wage team and consolidating enforcement of:

• National Minimum Wage (NMW) and National Living Wage (NLW)
• Statutory Sick Pay (SSP) — now day-one from April 6
• Holiday pay — with retrospective powers going back years
• Working time regulations

The FWA launches on April 7 with Matthew Taylor (author of the 2017 Taylor Review) as its Chair. It has walk-in enforcement powers — meaning officers can arrive unannounced at your premises, inspect records, and issue notices on the spot.

The penalty for NMW non-compliance: 200% of underpayment, up to £20,000 per worker.

Healthcare is explicitly named as a primary enforcement sector, alongside hospitality and social care.

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Why This Is a Double Crisis for Care Homes Specifically

Most sectors only face one of these pressures. Care homes face both — and they interact in a dangerous way.

Here's the specific risk:

1. Strike → Agency staff surge → Compliance unknown

When your regular staffing model fails, you fill gaps with agency workers. During NHS strikes, demand for agency nurses and care workers spikes sharply. In the rush to maintain safe staffing levels, you may take on workers whose compliance status you haven't verified.

The FWA can follow agency workers into your premises. If an agency worker is being paid below NMW — even if you're paying the agency properly — the FWA can investigate both you and the agency.

2. SSP becomes day-one from April 6

From the day before the strike starts, SSP is a day-one right for every worker. No more three-day waiting period. This means:

• Any employee off sick from April 6 is entitled to SSP from the first day
• You must record and pay SSP immediately — the FWA can check these records in a walk-in inspection
• Agency workers may also have SSP entitlements — check your contracts

3. Holiday pay records are now mandatory — with criminal sanctions

From April 6, the legal obligation to maintain holiday pay records is codified in UK employment law — and failure to maintain them is a criminal offence with unlimited fines. The FWA has retrospective powers: they can examine holiday pay records going back years.

If your payroll records are incomplete, or your holiday pay calculations are wrong (a very common issue in care due to irregular shift patterns), a walk-in FWA inspection starting April 7 could expose historic underpayments.

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The April 7 Care Home Action Checklist

You have 8 days. Here's what to do before the strike starts:

✅ 1. Payroll Audit — NMW and NLW Compliance

Check every worker is being paid at or above the current National Living Wage rate:

• Over 21: £12.71/hour (from April 1 2026)
• 18–20: £10.85/hour
• Under 18: £8.74/hour
• Apprentices: £7.55/hour

In care, the most common NMW failures are:

• Sleep-in shifts paid at a flat rate below £12.71 per hour
• Time spent travelling between visits not counted as working time
• Deductions for PPE or uniforms bringing pay below NMW
• Unpaid training time

Check your entire payroll — not just direct employees. If you use umbrella companies or staffing agencies, request written confirmation that all workers placed with you are NMW-compliant.

✅ 2. SSP Records — Update Your Process Today

From April 6, SSP applies from day one of absence. Update your process before the strike:

• Ensure your HR or payroll system is set to calculate SSP from day one
• Remove any waiting period from your sickness absence policy
• Ensure all managers know they must notify payroll of any absence from April 6 onwards
• For agency workers covering the strike: check whether their agency is handling SSP, or if any obligation falls on you

✅ 3. Holiday Pay Audit — Close the Records Gap

Holiday pay is the biggest hidden liability in care. Irregular shift patterns, overtime, and bank holiday payments create complex calculations that many providers get wrong.

Before April 7:

• Ensure you have clear written records of every worker's holiday entitlement, accrual, and payments for the last 3 years
• If you use an averaging method (12-week or 52-week for variable hours), document the calculation
• Audit for any workers on zero-hours contracts — their holiday pay is particularly easy to miscalculate

Red flag: If you have any zero-hours or irregular-hours workers and cannot immediately show your holiday pay calculation method, you have exposure.

✅ 4. Agency Staff Contracts — Read the Small Print

During the strike, you may take on agency workers in a hurry. Before doing so:

• Require written confirmation from the agency that all workers are paid NMW or above (including travel time)
• Ask for the agency's worker classification documentation — are they employed, worker, or self-employed?
• Retain a copy of the agency contract for FWA inspection purposes
• Check whether the agency has liability for SSP and holiday pay, or whether that passes to you

✅ 5. Prepare for a Walk-In Inspection

The FWA does not send advance notice. An enforcement officer can arrive at any time from April 7. Have these ready:

• Last 3 years of payroll records in accessible format
• Holiday pay calculation records
• SSP payment records
• Contracts for all current workers (including agency)
• Agency agreements and written compliance confirmations

If an FWA officer arrives during the strike when your site is at maximum pressure, having organised records could be the difference between a compliance notice and a £20,000-per-worker penalty.

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What Happens If You're Found Non-Compliant

The FWA has enforcement powers that go significantly further than the old HMRC NMW team:

Violation	Penalty
NMW underpayment	200% of underpaid amount, up to £20,000 per worker
Failure to maintain holiday records	Criminal offence — unlimited fine
SSP non-payment (from April 6)	HMRC enforcement + FWA coordination
Named and shamed	Published on gov.uk NMW enforcement list

For a care home, being named on the NMW enforcement list is particularly damaging — it appears in CQC inspection reports and affects your regulatory standing.

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The Bigger Picture: CQC Is Also Watching

The CQC has committed to completing 9,000 inspections by September 2026. That's a dramatic acceleration from recent years.

Five care services have been placed in special measures in the last two weeks alone — FiNN Homecare (Oxfordshire), Finch Manor (Liverpool), and three others. CQC inspectors are actively looking at staffing levels, safe recruitment, and — increasingly — whether providers are compliant with employment law during high-pressure periods like NHS strikes.

Employment law compliance and CQC ratings are no longer separate concerns. An FWA penalty that makes the news will be on an inspector's radar at your next assessment.

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Not Sure Where You Stand?

Before April 7, take our free Compliance Score quiz at compliancealert.co.uk/compliance-score. 20 questions, 3 minutes, instant results — covering NMW, SSP, holiday pay, and CQC readiness.

ComplianceAlert monitors FWA enforcement updates, NHS strike impacts, and CQC regulatory changes in real time — and sends you plain-English alerts before they affect your business.

Start your free 7-day trial today. No credit card required. 👉 compliancealert.co.uk/healthcare

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Key Dates Summary

Date	What Happens
1 April 2026	NLW rises to £12.71/hour — new minimum rate in force
6 April 2026	SSP becomes day-one right for all employees. Holiday pay records mandatory (criminal offence to omit).
7 April 2026	NHS resident doctors strike begins (7am). Fair Work Agency formally launches with walk-in powers.
13 April 2026	NHS strike ends (6:59am). FWA enforcement continues permanently.
12 June 2026	CQC sector-specific assessment framework consultation closes.

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TL;DR — 5 Things to Do Before April 7

1. Audit NMW compliance — especially sleep-in shifts, travel time, and deductions
2. Update SSP records — day-one from April 6, no more waiting period
3. Get holiday pay records in order — failure is a criminal offence from April 6
4. Get written NMW confirmation from all agencies before taking on strike cover staff
5. Prepare a walkable file of payroll and employment records for FWA inspection

The NHS strike and Fair Work Agency launch on the same day is not a coincidence — it is genuinely the most dangerous week for care home employment compliance in years. The window to prepare is now.

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ComplianceAlert monitors CQC, FWA, HSE, HMRC, and 12+ other UK regulators in real time. We send plain-English alerts to care home managers and healthcare providers before enforcement begins.

Take our free Compliance Score quiz: compliancealert.co.uk/compliance-score

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