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Governance · From 1 January 2025

Intentional underpayment: why documented escalation matters

The consequences of wage underpayment make clear ownership and timely correction essential business controls.

What changed

From 1 January 2025, intentional underpayment of wages or entitlements can be a criminal offence. Fair Work distinguishes intentional conduct from honest mistakes. Civil consequences may still arise from underpayments even where criminal intent is absent.

A control is more than a checklist

A review only helps if exceptions reach someone with authority to act. Document the issue, affected period, decision owner and correction plan. Do not let a repeated exception become accepted practice because it has appeared in earlier pay runs.

What leaders should ask

Can the team explain award and agreement decisions? Who checks significant variances? How are employee queries escalated? Is there evidence that known issues were investigated and resolved? These questions are relevant to in-house and outsourced delivery alike.

How SESAY can help

SESAY can introduce exception registers, review responsibilities and corrective-action tracking. Australian oversight supports escalation and communication; it does not remove the employer’s obligations or guarantee compliance.

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.