Periodic payroll audits
Payroll and timekeeping data ingested every pay period, classified against the applicable Wage Order and current case law, with violations flagged and corrective action documented.
The most rigorous PAGA reasonable-steps compliance file a California employer can maintain.
PAGA Shield assembles and continuously maintains a documentation-complete reasonable-steps compliance file — periodic payroll audits, corrective action records, written-policy dissemination logs, supervisor training records, and a rapid-response cure package — checked against the exact evidentiary standard of California's 2024 PAGA reform before a licensed attorney releases it.
Every element of AB 2288 / SB 92 reasonable-steps defenseFour statutory compliance components, gate-checkedPayroll audit · policy dissemination · training · corrective actionAttorney-directed engagement5-business-day SLA for cure packages
Why compliance files fail
A single missing element can cost millions in uncapped penalties.
California's 2024 PAGA reform created a brand-new statutory defense — 'all reasonable steps' — that caps penalties at 15% pre-notice and 30% post-notice if the employer can prove it maintained a documented program of periodic payroll audits, corrective action, written-policy dissemination, and supervisor training. Miss one element, and the caps vanish, exposing the employer to the full statutory penalty of $100–$200 per employee per pay period per violation.
Most employers rely on episodic, attorney-hourly-billed audits or generic timekeeping software that they operate themselves. Neither approach produces a continuously-maintained, attorney-reviewed evidentiary file that stands ready the day a PAGA notice arrives.
PAGA Shield exists to close that gap with a single, exhaustive standard applied identically to every file.
10,098
PAGA notices filed in 2025 — a record high
The benchmark
Measured against the letter of the statute — every component.
We do not summarize the law and hope. Every compliance file is scored against a versioned rule pack tied to the exact text of AB 2288 / SB 92 and the applicable Labor Code sections and Wage Orders. These are the components each file is held to.
Corrective action records
Each identified violation is paired with a documented corrective action — back wages paid, policy updated, training assigned — and timestamped for the evidentiary record.
Written-policy dissemination
Policies covering meal/rest breaks, overtime, expense reimbursement, and wage statements are disseminated to all nonexempt employees, with acknowledgment tracked and logged.
Supervisor training
Supervisors complete training on the employer's wage-and-hour policies and applicable legal requirements, with completion records maintained in the compliance file.
33/60-day cure windows
Upon receipt of a PAGA notice, a cure proposal and reasonable-steps evidence package is assembled within 33 days (or 60 days for certain violations) to qualify for the post-notice penalty cap.
Penalty cap calculation
Statutory exposure is calculated deterministically: $100 per employee per pay period for initial violations, $200 for subsequent, with caps applied only if all reasonable-steps elements are satisfied.
How a compliance file is built
Intake to attorney release, with deterministic gates the AI cannot overrule.
AI ingests payroll/timekeeping exports and classifies pay practices. Deterministic rules — running as code, outside the model — decide what is complete. A California-licensed employment attorney directs the engagement and signs every reasonable-steps characterization. That order is never reversed.
01
Compliance Gap Scan
Upload your payroll/timekeeping data and current policies. We return a free completeness read: which reasonable-steps components you already have, and which are missing.
02
Payroll audit & classification
As your authorized clerical agent, we ingest payroll exports every pay period, classify pay practices against the applicable Wage Order and current case law, and flag violations with penalty exposure.
03
Corrective action & documentation
Each flagged violation is paired with a corrective action plan — back wages, policy update, training assignment — and documented in the compliance file.
04
Deterministic completeness gates
Audit frequency, corrective-action timestamps, policy dissemination rates, and training completion are verified against the statutory standard. Any failure blocks release.
05
Attorney review & sign-off
A California-licensed employment attorney reviews the exception queue, directs any privilege-preserving adjustments, and signs the reasonable-steps characterization.
06
Delivery & continuous maintenance
You receive the compliance file: audit reports, corrective-action log, policy dissemination records, training completion certificates, and a standing evidentiary package ready for production upon PAGA notice.
The bar we hold
Rigor you can measure.
100%
Attorney-reviewed
No reasonable-steps characterization ships without a California-licensed employment attorney's sign-off.
5 days
Cure-package SLA
From notice intake to attorney-released cure proposal and evidence package.
<1%
Critical-defect target
Tracked against a gold-standard compliance file library.
4
Compliance components
Payroll audits · corrective action · policy dissemination · supervisor training, every applicable file.
Why PAGA Shield
Built to be the most thorough option an employer has.
Documentation-complete, by design
The deliverable is completeness itself — every statutory reasonable-steps component accounted for or explicitly exception-coded. Nothing is left implicit.
Deterministic, not vibes
The gates that decide completeness are code, not a model's opinion. A classification error cannot slip past a statutory requirement.
In its lane, on purpose
We prepare documentation and run audits as your clerical agent. We never give legal advice, contact employees, or represent you in any PAGA proceeding. Attorney direction preserves privilege.
Engagement
Flat fee, per employee per year. No hourly billing, ever.
Simple, predictable, and aligned with a compliance standard — not a cut of any penalty reduction.
- A free Compliance Gap Scan before you commit — see exactly what is missing.
- One flat fee per employee per year for continuous compliance file maintenance; disclosed pass-through costs for any third-party training platforms.
- Optional per-notice cure-package fee for rapid-response assembly upon receipt of a PAGA notice.
- No contingency and no percentage of any penalty reduction or settlement.
FAQ
Questions, answered precisely.
Is PAGA Shield a law firm?
No. PAGA Shield, a service of Your Deputy, Obuke LLC, provides documentation-completeness and compliance-file services. It is not a law firm, does not provide legal advice, and does not represent you in any legal matter. A California-licensed employment attorney directs the engagement and signs all reasonable-steps characterizations, preserving attorney-client privilege.
Do you contact employees or represent us in a PAGA action?
Never. PAGA Shield is not a law firm and does not contact employees or represent employers in any PAGA proceeding. The employer remains responsible for all legal representation and defense.
What makes a compliance file 'complete'?
Completeness is defined by the statute: periodic payroll audits with documented corrective action, disseminated written policies, trained supervisors, and corrective action against supervisors who violate policy. Deterministic gates enforce each component before the file is released.
How fast is the cure-package response?
The standard SLA is five business days from notice intake to an attorney-released cure proposal and evidence package, well within the 33/60-day statutory windows.
How are you priced?
A flat fee per employee per year for continuous maintenance, plus a per-notice fee for cure-package assembly. No hourly billing and no contingency.
See what's missing before a PAGA notice arrives.
Start with a free Compliance Gap Scan. Send your payroll/timekeeping data and current policies and we'll return a completeness read against every component of the AB 2288 / SB 92 reasonable-steps defense.
Documentation-completeness service · not legal advice · attorney-directed engagement preserves privilege.