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    California PAGA Reform 2024 (AB 2288/SB 92)

    California Labor Law Moves Fast.
    Move Faster.

    Whether you've received a notice or just want to sleep better, our forensic engine identifies your exact wage exposure—and the path to protection.

    Select your current status to see your mandatory deadlines and available penalty caps.

    Choose Your Situation(888) 843-0880

    $47M+

    Liability Reduced

    500+

    CA Employers Protected

    98%

    Cure Success Rate

    15+ Years

    CA Compliance Expertise

    Attorney-Privileged
    LWDA Compliant
    Courtroom-Ready
    SOC 2 Type II
    Source: CABIA Foundation / LWDA Data

    PAGA By The Numbers

    Real data from analyzed PAGA cases. These are the numbers plaintiffs' attorneys don't want you to see.

    $1.23M

    Avg. PAGA Court Case Cost

    Per employer settlement

    33%

    Goes to Plaintiffs' Attorneys

    ~$405K per case avg.

    2 Yrs

    Avg. Time to Resolve

    707 days in court

    6x

    Increase in PAGA Revenue

    $5.7M → $34.4M in 5 years

    Demand Letter Trap

    Plaintiffs' attorneys use threat letters to pressure employers into settling before a lawsuit is even filed. These settlements are never reported to LWDA or reviewed by any court — meaning there's no oversight that workers actually receive fair compensation.

    Bay Area Employers: Highest Risk

    Bay Area PAGA cases average $1.7 million per settlement — 38% higher than the statewide average. LA County represents 37% of all cases filed. If you operate in either region, your exposure is significantly elevated.

    Data: CABIA Foundation analysis of LWDA records, FY 2013/14 – FY 2017/18. Court case data per SB 836 reporting requirements.

    Why Act Now?

    PAGA Fund revenue grew 6x in five years ($5.7M to $34.4M), with reserves exceeding $113 million. Lawsuit volume is accelerating — and under the 2024 reforms, employers who audit before receiving a notice lock in penalty caps that are unavailable once the letter arrives. Every day without a proactive audit is a day closer to full exposure.

    Protect My Business Now
    Deadline Calculator

    When Did You Receive The Letter?

    Enter the date on your LWDA notice letter. We'll calculate every critical deadline and tell you exactly what to do next.

    This is the date printed on the certified LWDA notice you received.

    Four-Scenario Defense Framework

    Select the scenario that matches your current situation to see your mandatory deadlines and available penalty caps.

    PROACTIVE
    Click to expand

    The Preventative Shield

    Proactive Audit Before Notice

    BEFORE NOTICE

    Lock in 15% penalty cap

    Who this is for: Employers who have NOT received a notice but want to protect their enterprise.

    Lock in the lowest possible penalty cap of 15% by demonstrating "reasonable steps" before any notice arrives.

    Click to see full details, timeline, and deliverables

    URGENT
    Click to expand

    Violation Notification

    Post-Notice Response

    33 DAYS

    From date of LWDA notice

    Who this is for: Employers who just received a certified LWDA notice letter.

    Cap your penalties at 30% and potentially prevent the lawsuit from ever being filed.

    Click to see full details, timeline, and deliverables

    LITIGATION
    Click to expand

    Active Litigation Defense

    Post-Lawsuit Strategy

    IMMEDIATE

    Request EEC + stay proceedings

    Who this is for: Employers who have been served with a civil complaint.

    Aim for penalty cap of $15 per pay period or total dismissal via Standing Challenge.

    Click to see full details, timeline, and deliverables

    DEFENSE
    Click to expand

    Traditional Wage & Hour Defense

    Non-PAGA Wage Lawsuits

    VARIES

    4-year lookback (PAGA + wage + UCL)

    Who this is for: Non-PAGA wage lawsuits where 100% of recovery goes to plaintiff.

    Minimize total exposure by eliminating overlapping and derivative claims.

    Click to see full details, timeline, and deliverables

    Why Forensic Analysis

    Standard Reports Hide the Truth

    Your payroll system wasn't designed to protect you from PAGA claims. Our forensic approach was.

    Temporal Handshake

    Standard payroll reports hide errors. We use forensic sequencing to find the truth—even if your data is missing dates. Every punch-in, break, and meal is reconstructed to find the invisible violations.

    2026 Multipliers

    Don't let a $1,300 error turn into a $10,000 penalty. Our Cure Cards are calibrated for 2026 interest rates and SB 261 protection—the exact math you need to demonstrate "Reasonable Steps."

    Team analyzing forensic data

    Expert Analysis

    Our team identifies hidden wage gaps before they become costly lawsuits.

    Calculate Your PAGA Exposure

    Marketing vs. Reality

    What your payroll provider tells you vs. what actually happens in a California audit

    What Your Payroll Provider Says
    The Reality of a California Audit
    Your checks are printed correctly.
    Doesn't matter if the meal was 1 minute late.
    We handle your taxes.
    They don't handle your § 203 Waiting Time penalties.
    You have an OT report.
    It doesn't link to the Regular Rate of Compensation (RRC).
    You're Safe.
    You're a target until you have a Forensic Cure Card.

    How We Protect You

    A systematic approach conducted by our compliance experts on your behalf

    01

    Data Collection

    We gather your payroll records, time data, and employee classifications.

    02

    Forensic Analysis

    Our compliance team uses forensic sequencing to find hidden violations.

    03

    Cure Calculation

    We calculate exact principal, 7% interest, and liquidated damages owed.

    04

    Certification

    You receive your 'Certification of Reasonable Steps' documentation.

    Interactive Tools

    Interactive Audit Tools

    Use these tools to assess your risk and build your defense strategy.

    Exposure Calculator

    Max Autonomy Tool

    Input # of employees and pay periods to see your total liability across Cure, Litigation, and Treble tiers.

    Powered by

    Relief Toggle Suite

    Calculate Exposure

    Standing Checker

    Max Autonomy Tool

    Input plaintiff's name and specific allegations to validate their legal standing.

    Powered by

    Standing Validator

    Check Standing

    Cure Math Portal

    Max Autonomy Tool

    Upload raw data for "Make-Whole" math including 3-year back pay and 7% interest.

    Powered by

    Cure Proposal Generator

    Start Cure Math
    Compliance Guarantee

    Your Best Defense is a Proactive Cure

    "In California, the best defense is a proactive cure. Our system provides the mathematical proof required to certify that your business has taken 'All Reasonable Steps' to comply with the Labor Code."
    85%

    Penalty reduction with proactive audit

    60 Days

    Cure window after receiving notice

    $200→$15

    Per pay period penalty reduction

    Schedule Free Consultation(888) 843-0880

    "PAGA IQ identified $2.3M in ghost liability we didn't know existed. We cured before the lawsuit was filed."

    JR

    James R.

    CFO, Healthcare Group

    "The 33-day cure window saved us over $800K in potential penalties. Best investment we've made."

    MS

    Maria S.

    HR Director, Manufacturing

    "Our payroll provider missed meal break violations for 3 years. Easeworks found them in 48 hours."

    DL

    David L.

    CEO, Retail Chain

    "After a competitor got hit with a $1.5M PAGA suit, we got proactive. Now we sleep at night."

    SK

    Sarah K.

    Operations VP, Logistics

    "The forensic audit paid for itself 50x over. We locked in the 85% penalty discount."

    MT

    Michael T.

    Owner, Restaurant Group

    "Attorney-privileged protection gave us confidence to audit without creating liability."

    JW

    Jennifer W.

    General Counsel, Tech Startup

    "PAGA IQ identified $2.3M in ghost liability we didn't know existed. We cured before the lawsuit was filed."

    JR

    James R.

    CFO, Healthcare Group

    "The 33-day cure window saved us over $800K in potential penalties. Best investment we've made."

    MS

    Maria S.

    HR Director, Manufacturing

    "Our payroll provider missed meal break violations for 3 years. Easeworks found them in 48 hours."

    DL

    David L.

    CEO, Retail Chain

    "After a competitor got hit with a $1.5M PAGA suit, we got proactive. Now we sleep at night."

    SK

    Sarah K.

    Operations VP, Logistics

    "The forensic audit paid for itself 50x over. We locked in the 85% penalty discount."

    MT

    Michael T.

    Owner, Restaurant Group

    "Attorney-privileged protection gave us confidence to audit without creating liability."

    JW

    Jennifer W.

    General Counsel, Tech Startup

    Frequently Asked Questions About PAGA

    Answers to the most common questions California employers ask after receiving a PAGA notice.

    I just got a PAGA notice — what do I do first?
    Don't panic, but act fast. You have critical deadlines starting at Day 33. The first step is to determine whether you qualify for a Proposal to Cure (employers with fewer than 100 employees). Then begin documenting corrective actions immediately — the clock is running on your 'reasonable steps' defense, which can cap your penalties at just 15% of the statutory maximum.
    How far back can a PAGA lawsuit go?
    The total audit lookback is 4 years. PAGA itself has a 1-year statute of limitations, but the underlying wage claims go back 3 years, and the Unfair Competition Law (Bus. & Prof. Code §17200) claim — which is almost always filed alongside PAGA — adds another year. That's why a forensic audit needs to cover the full 4-year window.
    What is the 33-day cure deadline?
    Under SB 92 (PAGA Reform 2024), employers with fewer than 100 employees can submit a confidential Proposal to Cure to the LWDA within 33 days of the original notice. If accepted, this can resolve the claim before litigation. It's your earliest and most cost-effective defense window.
    What happens after the LWDA's 65-day investigation window?
    The LWDA has 65 days from the notice to decide whether to investigate independently. If they decline to act or the 65 days expire without action, the employee's attorney can then file a civil PAGA lawsuit in court. This is the earliest point at which you can be sued — not before.
    How much does the average PAGA lawsuit cost an employer?
    The average PAGA court case costs employers $1.23 million. Of that, approximately 33% ($405K) goes to the plaintiff's attorney, not to the workers. However, under the 2024 reforms (AB 2288), employers who demonstrate 'reasonable steps' before receiving a notice can cap penalties at just 15% of the statutory maximum — reducing a $1.23M exposure to roughly $185K.
    What are 'reasonable steps' and how do they reduce penalties?
    Under AB 2288, employers who took 'reasonable steps' to comply with labor laws before receiving a PAGA notice qualify for the lowest penalty tier — just 15% of the statutory maximum. This includes things like regular payroll audits, documented compliance policies, corrective action on known issues, and employee training. The key is proving these steps were in place before the notice arrived.
    Can I settle a PAGA case?
    Yes, but PAGA settlements require court approval and must include the LWDA's 75% share of civil penalties. Settlement vs. trial is a strategic decision that depends on your exposure level, the strength of your 'reasonable steps' defense, and whether you filed a timely Proposal to Cure. A forensic audit helps quantify your actual exposure so you can make an informed decision.
    Do I need a lawyer for a PAGA claim?
    Yes. PAGA claims involve complex California labor law, mandatory government filings, and specific statutory deadlines. However, pairing legal counsel with a forensic payroll audit dramatically strengthens your defense — your attorney gets precise exposure data, documented corrective actions, and evidence of 'reasonable steps' that directly reduce penalties under the 2024 reform law.

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