September 10, 2025 • News

USDOL Relaunches PAID Self-Audit Program

In April 2018, the U.S. Department of Labor (DOL) Wage and Hour Division (WHD) launched a nationwide pilot program to facilitate the resolution of potential overtime and minimum wage violations under the Fair Labor Standards Act (FLSA) without litigation. The Payroll Audit Independent Determination (PAID) program allowed employers to proactively self-audit to identify potentially non-compliant compensation practices. On July 24, 2025, WHD announced that PAID has been relaunched and has been expanded to include the Family and Medical Leave Act (FMLA).

To be eligible to apply to participate in PAID, employers must be:

• covered by FLSA and/or FMLA, and
• interested in proactively resolving potential minimum wage, overtime, tip retention and/or FMLA claims, and
• willing to commit to future compliance under FLSA and/or FMLA

Additionally, employers may not currently be party to any litigation (e.g., private, with WHD, or with a state enforcement agency) related to, be under investigation by WHD for, or have knowledge of complaints about compensation in, the proposed self-audit. 

For more information on employer eligibility, see the PAID site.

Eligible employers that wish to participate in PAID must:

• complete an online Compliance Assistance Review about FLSA and/or FMLA, as applicable, and obtain a system-generated Certificate of Completion upon completion;
• specifically identify the potential violations, employees affected, and timeframes each employee was affected;
• calculate the amount of back wages owed to each employee, if applicable; 
• report to WHD their findings, calculations, remedies due, supporting evidence, and methodology
• After WHD evaluates the employer’s self-audit and issues a summary of unpaid wages, employers must pay back wages and/or remedies to employee(s) within 15 days of receiving the summary and provide proof of payment and documentation of other remedies to WHD.

For more information, see the PAID site.