All resources

Enforcement · Penalty decision reported February 2024

The CBA and CommSec case: reconciliation must lead to action

Large organisations can experience serious payroll failures. Scale and location do not substitute for effective review.

The regulator’s outcome

The Fair Work Ombudsman reported $10.34 million in penalties against Commonwealth Bank and CommSec in February 2024. The matter involved obligations under enterprise agreements and arrangements intended to leave employees better off overall. Read the linked penalty release for the findings and scope.

The practical lesson

Payroll controls need to test the actual entitlement against the amount paid and trigger correction when there is a shortfall. A salary or an established arrangement should not end the analysis. This case does not establish that local payroll teams are inherently incapable.

Questions for your next review

Which employees require comparison calculations? How is actual time captured? Who signs off the reconciliation and any top-up? Where is the evidence retained? A recurring control should specify the population, timing, calculation method and escalation owner.

How SESAY can help

SESAY can support reconciliation packs, exception investigation and documented review. Complex instrument interpretation and historical remediation should be separately scoped with appropriate expertise.

Discuss your payroll requirements

Official sources & further reading

General information, current at the review date. Check the linked regulator guidance for your circumstances and any later changes. SESAY service scope and authorisations are agreed before commencement.