This move is part of a broader WHD shift toward cooperative enforcement. PAID is merely the latest step in a series that has also included, for example, the return of opinion letters and a pullback on liquidated damages in administrative cases...
Seyfarth Synopsis: The U.S. Department of Labor has officially revived its Payroll Audit Independent Determination (PAID) program. Designed to help employers proactively resolve FLSA issues—and now, for the first time, certain FMLA violations—the renewed program offers potential benefits but comes with conditions and risks that require careful navigation.
On July 24, 2025, the DOL's Wage and Hour Division (WHD) announced the re-launch of the PAID program. Originally rolled out in 2018 under the first Trump Administration (and discontinued by the Biden DOL a few years later), PAID aims to encourage employers to self-identify and correct compliance issues under the FLSA and FMLA.
This move is part of a broader WHD shift toward cooperative enforcement. PAID is merely the latest step in a series that has also included, for example, the return of opinion letters and a pullback on liquidated damages in administrative cases.
The DOL's message seems clear: Proactive compliance efforts are encouraged and will be rewarded.
But as always, the details matter.
How the PAID Program Works
PAID is a voluntary program through which employers conduct a self-audit, disclose findings to WHD, and—if accepted into the program—resolve potential...
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