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Documentation is Key: Employers should maintain thorough records of every audit, training, policy review and corrective action taken. This documentation will be critical to showing the employer has consistently taken reasonable steps to comply with labor laws. Records of wage statement reviews, employee notices and payroll corrections should be kept for the applicable statute of limitations—up to four years for wage claims​.

measures—they must be part of an ongoing strategy that embeds compliance into the day-to-day operations of the business. In a PAGA lawsuit, employers who can show they’ve consistently taken “all reasonable steps” have a powerful defense against the high penalties typically associated with such claims. By embracing this approach, employers can both mitigate their financial exposure and create a more compliant, employee-friendly workplace.

The Bottom Line: Prioritize Proactive Compliance The PAGA reforms have created a significant opportunity for employers to mitigate their risk, especially if they take proactive steps before being served with an LWDA notice or an employee’s records request. The key to unlocking these benefits lies in regularly reviewing and updating policies, conducting audits, training supervisors and documenting every action. These are not just reactive

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