Minimum Wage Comparison: UK, FR, AU, NZ, CA, US 2026

Last verified: 2026-05-02

In 2026, statutory minimum wages in the seven jurisdictions MmowW Scrib🐮 covers range from the US federal floor of USD 7.25/hour (unchanged since 2009) to Australia’s A$24.95/hour. This guide gathers the current rates, the statutes that set them, and the practical compliance traps for employers preparing employment contracts and pay slips.

Quick Answer (TL;DR)

Comparison Table at a Glance

Country-by-Country Deep Dive

United Kingdom — National Minimum Wage / National Living Wage (1 April 2026)

The UK has age-banded rates set under the National Minimum Wage Act 1998 and uprated annually by Regulations on the recommendation of the Low Pay Commission.

Rates from 1 April 2026:

Statutory enforcement. HMRC enforces the NMW/NLW. Civil penalties for underpayment are 200% of the underpayment (capped at £20,000 per worker), and the employer is “named and shamed” on a public register. Workers can also claim through the Employment Tribunal.

Source:

• NMW Act 1998: https://www.legislation.gov.uk/ukpga/1998/39/contents
• Government rates page: https://www.gov.uk/national-minimum-wage-rates

France — SMIC (1 January 2026)

The Salaire Minimum Interprofessionnel de Croissance (SMIC) is set under Code du travail art. L.3231-1 et seq. and revalued each 1 January (and ad-hoc on inflation if CPI rises by ≥2% during the year).

Rates from 1 January 2026 (Décret n°2025-1228 du 17 décembre 2025):

Applies to métropole + Guadeloupe + Guyane + Martinique + La Réunion + Saint-Barthélemy + Saint-Martin + Saint-Pierre-et-Miquelon. Mayotte has its own SMIC (different rate).

Critical caveat — convention collective. Under Code du travail L.2253-3 (principe de faveur), if a sectoral collective bargaining agreement (convention collective) sets a minimum higher than the SMIC, the convention prevails. For example, the Syntec convention for IT/engineering sets minimums above SMIC. Failing to apply the convention triggers URSSAF redressement (back-payment + penalties).

Sources:

• Décret n°2025-1228: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053042520
• Service-Public.fr SMIC: https://www.service-public.fr/particuliers/vosdroits/F2300

Australia — National Minimum Wage (1 July 2025)

The Fair Work Commission sets the National Minimum Wage annually under the Fair Work Act 2009 (Cth), s.285 through the Annual Wage Review.

Rate effective 1 July 2025 (until 30 June 2026):

Critical hierarchy. Most Australian employees are covered by a modern award (122 awards as at 2026). The award rate is generally higher than the National Minimum Wage. Employers must pay the higher of:

1. The applicable modern award rate (s.293)
2. The National Minimum Wage (s.294)

Casual loading (s.15A Fair Work Act 2009). A casual employee is paid an additional 25% loading to compensate for lack of paid annual and personal leave entitlements. The casual loading applies on top of the relevant minimum or award rate.

Source:

• Fair Work Commission: https://www.fwc.gov.au/work-conditions/minimum-wages-and-conditions/national-minimum-wage
• Fair Work Ombudsman pay rates: https://www.fairwork.gov.au/pay-and-wages/minimum-wages

New Zealand — Minimum Wage Order 2026 (1 April 2026)

The Minimum Wage Order 2026 comes into force on 1 April 2026 under the Minimum Wage Act 1983.

Key difference from UK. NZ has no general youth minimum wage for 16+ year-olds outside the starting-out and training criteria. A 17-year-old not in the starting-out scheme must be paid the full adult rate.

Sources:

• Minimum Wage Act 1983: https://www.legislation.govt.nz/act/public/1983/0115/latest/DLM74093.html
• Minimum Wage Order 2026: https://www.legislation.govt.nz/secondary-legislation/pco-drafted/2026/16/en/latest/
• Employment NZ: https://www.employment.govt.nz/pay-and-hours/pay-and-wages/minimum-wage/minimum-wage-rates-and-types

Canada — Federal vs Provincial

Canada has a federal minimum wage for federally regulated industries (banks, telecoms, interprovincial transport) plus separate provincial minimum wages for everything else.

Federal (effective 1 April 2026 — indexed to CPI):

• CAD $17.75/hour under the Canada Labour Code

Provincial highlights:

• Ontario: CAD $17.20/hour general (effective 1 October 2025) under Employment Standards Act 2000
• British Columbia: CAD $17.85/hour (effective 1 June 2025)
• Alberta: CAD $15.00/hour (last increased 1 October 2018)
• Quebec: CAD $16.10/hour (effective 1 May 2025)

Application rule. A Canadian employee is entitled to the higher of the federal minimum (if federally regulated) or the provincial minimum (otherwise).

Sources:

• Canada Labour Code minimum wage: https://www.canada.ca/en/employment-social-development/services/labour-standards/minimum-wage.html
• Ontario ESA: https://www.ontario.ca/document/your-guide-employment-standards-act-0/minimum-wage

United States — Federal Floor + 50 State Rules

The Fair Labor Standards Act (29 USC §206) sets the federal minimum wage. Many states and cities set higher rates:

Federal: USD 7.25/hour — unchanged since 24 July 2009 (the longest period without an increase in US history).

Selected state and city rates (illustrative, as of 1 January 2026):

Application rule. A US employee is entitled to the highest applicable rate — federal, state, or city/county. Tipped employees have lower direct cash wage minimums under federal law (USD 2.13/hour federal) but the employer must “make up” any shortfall to reach the full minimum.

Sources:

• Fair Labor Standards Act 29 USC §206: https://www.law.cornell.edu/uscode/text/29/206
• US DOL Wage and Hour Division: https://www.dol.gov/agencies/whd/minimum-wage

Decision Framework — How Does My Country’s Minimum Wage Compare?

Highest gross hourly minimum (USD-equivalent, 2026):

1. Australia ≈ USD 16.50/hour
2. UK ≈ USD 16.30/hour
3. New Zealand ≈ USD 14.20/hour
4. Canada (federal) ≈ USD 13.00/hour
5. France ≈ USD 12.90/hour (gross, 35h base)
6. US (federal) USD 7.25/hour

Highest including statutory loadings:

• Australia casual loaded → USD ~20.50/hour
• France with employer charges (~+42% at SMIC) → USD ~18.30/hour total cost
• UK with employer NIC and pension → USD ~17.50/hour total cost

Lowest predictability of future increases:

• US federal — fixed by Congress; unchanged since 2009
• All other six countries have automatic or annual review mechanisms

Common Pitfalls — Gyoseishoshi View

1. France: applying SMIC when a higher convention collective minimum applies. URSSAF audits frequently catch employers paying SMIC when the convention de branche (e.g., Syntec, Métallurgie) sets a higher floor for the position’s classification. The principle of faveur means the higher of statute and convention always applies (C. trav. L.2253-3).

2. Australia: paying NMW when a modern award applies. 122 modern awards cover most employees. Paying the National Minimum Wage when an award sets a higher rate breaches Fair Work Act 2009 s.45 / s.293.

3. US: forgetting tipped credit limits. Federal allows USD 2.13/hour direct cash for tipped employees — but only if the worker’s tips bring the total to USD 7.25. Many states (CA, OR, WA, NV, MN, MT, AK) prohibit any tip credit.

4. UK: applying the wrong NMW age band. The bands change on 1 April. A 20-year-old paid £10.85 on 31 March who turns 21 on 2 April must be paid £12.71 from 2 April.

5. NZ: missing the starting-out criteria. Starting-out and training rates (NZ$19.16 from 1 April 2026) apply only to specific qualifying conditions. A general 17-year-old retail employee, not in starting-out, gets the full adult rate of NZ$23.95.

6. Canada: federal vs provincial confusion. A bank teller in Ontario is federally regulated → federal minimum CAD $17.75. A retail clerk in Ontario is provincially regulated → Ontario ESA CAD $17.20. Same physical location, different statutes.

Conclusion

Statutory minimum wages in 2026 cluster in two groups:

• High-wage common law / EU jurisdictions — Australia, UK, NZ, France, Canada all sit between USD 13–17/hour and have automatic or annual review mechanisms.
• The US outlier — Federal floor of USD 7.25/hour has been unchanged since 2009. State and city minimums are doing the work.

For employers running multi-country payroll, the trap is not the rate itself — it is the layered hierarchy: federal vs state vs provincial in Canada/US, NMW vs award in Australia, SMIC vs convention collective in France, and the age-banded UK regime.

When you sign an employment contract, always state the rate in writing, the jurisdiction’s statute that governs it, and the date the rate was last verified.

Multi-Country Documents with Scrib🐮

One platform, 18 document types, 7 countries. Scrib🐮 covers UK, US, Canada, Australia, New Zealand, France, and Sweden. ¥22,000/month pass — unlimited access to all 18 document types across 7 countries. Start Free Preview →

Disclaimer

Legal information, not legal advice. MmowW Scrib🐮 is operated by a licensed Gyoseishoshi (行政書士) office in Japan. We are not solicitors, barristers, attorneys, avocats, or licensed legal practitioners in any jurisdiction.

Sources

1. UK — National Minimum Wage Act 1998: https://www.legislation.gov.uk/ukpga/1998/39/contents
2. UK — gov.uk minimum wage rates: https://www.gov.uk/national-minimum-wage-rates
3. France — Code du travail L.3231-1: https://www.legifrance.gouv.fr/codes/article_lc/LEGIARTI000006902801
4. France — Décret SMIC 2026: https://www.legifrance.gouv.fr/jorf/id/JORFTEXT000053042520
5. France — Service-Public.fr SMIC: https://www.service-public.fr/particuliers/vosdroits/F2300
6. Australia — Fair Work Act 2009 (Cth): https://www.legislation.gov.au/Series/C2009A00028
7. Australia — Fair Work Commission: https://www.fwc.gov.au/work-conditions/minimum-wages-and-conditions/national-minimum-wage
8. Australia — Fair Work Ombudsman: https://www.fairwork.gov.au/pay-and-wages/minimum-wages
9. New Zealand — Minimum Wage Act 1983: https://www.legislation.govt.nz/act/public/1983/0115/latest/DLM74093.html
10. New Zealand — Minimum Wage Order 2026: https://www.legislation.govt.nz/secondary-legislation/pco-drafted/2026/16/en/latest/
11. Canada — Canada Labour Code minimum wage: https://www.canada.ca/en/employment-social-development/services/labour-standards/minimum-wage.html
12. Canada (Ontario) — ESA 2000: https://www.ontario.ca/document/your-guide-employment-standards-act-0/minimum-wage
13. United States — FLSA 29 USC §206: https://www.law.cornell.edu/uscode/text/29/206