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Wednesday, April 2, 2025

How to Conduct a PAGA Audit: 5 Key Areas California Employers Must Review - California Employment Law Report

California’s 2024 reform to the Private Attorneys General Act (PAGA) was intended to ease the burden on employers—but only for those who can demonstrate a real, documented effort to comply with wage and hour laws.

Under the revised law, employers now face reduced penalties if they take proactive steps to comply:

  • 15% of the applicable penalties if the employer took reasonable steps to comply before receiving a PAGA notice or a request for employment records
  • 30% of the applicable penalties if the employer took reasonable steps to comply within 60 days after receiving a PAGA notice

In both cases, the key phrase is “reasonable steps to comply”—and that’s where a PAGA audit comes in.

A thorough internal review, supported by legal counsel if needed, helps employers identify and correct compliance issues before they result in a claim. And if a claim does arise, an audit report and supporting documentation may help reduce penalties and demonstrate good faith.

Our law firm’s PAGA Compliance Audit and Certification Program focuses on many aspects of compliance, and here are five key areas most California employer should evaluate as part of their compliance strategy:

1. Payroll and Timekeeping Practices

PAGA claims frequently target wage-related issues, especially rounding practices, inaccurate time records, or missed overtime. Employers should evaluate:

  • Whether time rounding practices comply with recent court decisions
  • Accuracy of timekeeping systems, especially for remote or...


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