12 November 2026

National Australia Bank Ltd (NAB) is completing payments of $127 million, plus $34 million in interest and $8 million in superannuation, to 65,999 underpaid workers as part of entering into an Enforceable Undertaking (EU) with the Fair Work Ombudsman.

The bank will also make a $2 million contrition payment to the Commonwealth Consolidated Revenue Fund and has committed to a range of measures aimed at ensuring it complies with workplace laws in future.

The contrition payment is the largest ever included in an Enforceable Undertaking executed by the Fair Work Ombudsman. NAB’s undertaking also includes terms never before included in a FWO EU that commit it to comprehensive planning and implementation of any future enterprise agreement.

NAB underpaid workers across all states and territories in Australia over more than a decade.

Back-payments to impacted individual workers range from less than $5 to more than $87,000, including superannuation and interest, with an average back-payment of about $1,934.

NAB first self-reported underpayments to the Fair Work Ombudsman in late 2019, after it became aware that it had made significant errors in implementing its then most recent enterprise agreement.

This prompted NAB to conduct a broad review of employee entitlements that identified non-compliance issues dating back to 2012.

Years later, when implementing a new enterprise agreement in 2024, NAB became aware it had failed to identify and rectify its non-compliance issues adequately, which had resulted in it continuing to underpay staff.

Underlying causes of NAB’s underpayments included deficiencies in governance processes and compliance oversights, inadequate record-keeping, legacy payroll technology, and limited investment in specialist capability relevant to payroll operations.

This resulted in non-compliance issues, including NAB’s failure to conduct regular reconciliation checks required under the terms of its enterprise agreement and to pay any shortfalls identified from comparing wages paid with amounts eligible employees would have received under the Banking, Finance and Insurance Award 2010.

Other basic failings included NAB not adequately capturing time-and-attendance data for staff, not accruing staff leave correctly, and the misapplication and non-application of various entitlements under successive enterprise agreements.

NAB underpaid its employees a range of entitlements, including minimum wages for ordinary hours; payments related to penalty rates, shift loadings, and overtime; allowances such as meal and standby allowances; payments on termination; annual, personal and long-service leave entitlements; and superannuation.

A broad range of casual, part-time and full-time staff were underpaid, including staff from various roles across personal and business banking, including customer and business support advisors, quality assurance and risk analysts, credit assessment and private banking associates, business and home lending bankers, digital and product consultants, branch and business managers and project managers.

NAB has rectified the large majority of the identified underpayments, which occurred between 2012 and 2026.

The bank has so far paid at least $155 million to current and former employees, which includes underpaid wages and entitlements exceeding $120 million, interest on top of this of more than $25 million, and more than $8 million in applicable superannuation.

Fair Work Ombudsman Anna Booth said an Enforceable Undertaking was appropriate as NAB had cooperated with the FWO’s investigation, would be fully rectifying its underpayments, and had committed to improving its compliance and governance settings and controls.

“NAB’s underpayments highlight the serious, long-running problems that can arise when an employer fails to coordinate key business functions to meet their workplace obligations, including payroll, industrial relations, technology, risk management, audit and legal,” Ms Booth said.

“It’s particularly disappointing to see these types of large and long-running underpayment issues in such a well-resourced employer, including where it negotiated its own legally enforceable enterprise agreement terms but failed to make sure it had in place fully compliant payroll systems capable of giving effect to those terms before they became operational.

“Complying with workplace laws is an organisation-wide responsibility, and planning for compliance with new enterprise agreement terms should begin early to ensure workers receive what they are owed.

“We welcome however NAB’s extended efforts and reviews across many years to ensure it finds and rectifies all underpayments. The Enforceable Undertaking ensures comprehensive remediation – covering timeframes well outside statutory limits – as well as stronger accountability and sustained future compliance.

“The Undertaking requires NAB to address the underlying causes of its failures and to strengthen its compliance across its governance systems. These commitments include, for the first time in a FWO EU, early planning to implement any new enterprise agreement, through a steering committee chaired by NAB’s Group Executive People and Culture.

“In addition, the Undertaking requires stronger executive oversight and reporting of employee complaints and non-compliance, supported by improved systems and processes to identify any trends and emerging areas of non-compliance revealed within employee complaint and reporting channels, before they become systemic.

“Improving compliance among large corporates is a Fair Work Ombudsman priority. We’ve helped recover more than $1.2 billion for workers from large corporates over the past five financial years.”

Measures NAB has committed to under the Enforceable Undertaking include:

• establishing a steering committee, chaired by the Group Executive People and Culture, to oversee the planning and operationalisation of any new enterprise agreement, including ensuring its systems and processes are capable of effectively implementing all requirements of the new agreement;
• engaging an independent auditor to assess preliminary and full compliance of a new payroll platform that will be implemented, and reporting the audit findings to the FWO;
• improving systems and processes to identify non-compliance trends in employee complaints, and to monitor complaints from receipt to resolution including response timeframes. NAB must report to the FWO on these improvements;
• committing to worker-voice initiatives, including regular staff forums and promoting channels for employees to raise concerns;
• completing a broader payroll review program, overseen by Group Executives, and rectifying any further underpayments;
• developing systems for regularly informing its Board of compliance matters;
• industry initiatives to share experiences and learnings regarding workplace relations compliance;
• delivery of mandatory training for recording additional hours worked and any new replacement agreement;
• informing employees of the Enforceable Undertaking via a media release on its website, intranet and social media and making a further written apology to current employees; and
• making a $2 million contrition payment to the Commonwealth Consolidated Revenue Fund.

NAB will pay entitlements arising under the Fair Work Act owing to underpaid workers it is unable to locate to the Commonwealth of Australia unclaimed monies account, which anyone can search to check whether unpaid wages are being held for them.

Employers and employees can call the Fair Work Infoline on 13 13 94 or visit www.fairwork.gov.au for free advice and assistance. An interpreter service is available on 13 14 50. Workers can also seek information from their employer, or their union if they are a member.

Employers can seek information from their employer association if they are a member.

Employers can seek guidance on how to fix underpayments, including access to tools and resources such as the Payroll Remediation Program Guide, on the FWO’s website.

The Fair Work Commission (FWC), a different organisation from the Fair Work Ombudsman, is the national workplace relations tribunal and has a range of roles in relation to bargaining and the making of enterprise agreements. Further information regarding enterprise agreements is available on the FWC’s website.