The Regulation of Wages (General) (Amendment) Order, 2026 — Legal Notice 108, in operation from 1 May 2026 — sets a minimum wage for every listed occupation in three forms: per month, per day and per hour. Most employers read the column that matches how they pay and stop there.
The heading above those columns is the part that catches people out. It says:
Basic minimum monthly wages (exclusive of housing allowance) and minimum daily and hourly rates (inclusive of housing allowance).
Two different treatments, in one table, under one heading.
What that means in practice
A general labourer in Nairobi, Mombasa, Kisumu, Nakuru or Eldoret is gazetted at 18,047.40 a month, 868.44 a day and 161.34 an hour.
If you employ that person monthly, 18,047.40 is not what you pay. House allowance sits outside it. At the common convention of 15% of basic, the actual monthly floor is closer to 20,754. An employer paying 18,047.40 and calling it compliant is roughly 15% short, every month, for every person on that grade.
If you engage the same person by the day, 868.44 is the whole figure. House allowance is already inside it. Adding 15% on top is not generous — it is a misreading in the other direction, and it quietly raises your cost per worker-day on every site.
The second trap: the columns are not versions of each other
It is tempting to treat the monthly rate as the real number and derive the others from it. The arithmetic looks reasonable — 18,047.40 × 12 ÷ 365 is about 593 a day — and it is wrong by nearly 300 shillings.
The order prices a casual day higher on purpose. A day of casual work carries no annual leave, no sick pay, no notice, no public holidays and no severance. The day rate compensates for their absence. Dividing a monthly figure down strips out that compensation and pays for none of it.
So the rule is to read down a column, never across one:
- a monthly employee is measured against the monthly figure, plus house allowance
- a casual is measured against the daily or hourly figure, as published
Where this shows up
It shows up in three places, usually in this order.
At engagement. A site supervisor agrees a day rate against a monthly figure somebody divided down. Nobody notices, because the rate still looks like a reasonable number.
At the wage bill. Finance budgets on the rate that was quoted and the bill arrives higher, or the workforce is underpaid and nobody has the figure to prove it either way.
At an inspection. A labour officer reads the order the way the order is written. The conversation is then about arrears rather than about process.
What to check this week
Pull your current rates for every grade you engage, and put three questions to each one:
- Is this person paid monthly, daily or hourly?
- Which gazetted column does that rate belong in?
- If monthly — is house allowance being paid on top, or has it been assumed to be inside?
Most of the gaps we find are question three.
Farms are a separate order
Agricultural employees fall under Legal Notice 109, not 108. That order sets a single consolidated national figure rather than splitting by area, and it publishes monthly and daily rates only. Applying the general order to a farm — or the agricultural order to a packhouse that is not one — is its own category of error.
Working it out
Our casual and minimum wage calculator holds both orders as gazetted. Pick the area and the occupation, say how the person is paid, and it shows the floor for that basis beside what you are actually paying — with house allowance added on a monthly rate and left alone on a daily one, because that is what the order says.
If the answer surprises you, it is worth a conversation before it is worth a correction.
ACCUREX is a Nairobi HR consultancy. PiPO HRIS is its workforce platform, built out of the problems its consulting practice kept meeting on client sites.