Starting April 9, 2025, Ohio employers must comply with new payroll transparency rules under House Bill 106 — officially known as the Pay Stub Protection Act. This new law requires employers to include specific information on each employee’s pay statement. If your business operates in Ohio and issues wages to employees, this law impacts you directly.
Failing to meet these new requirements can lead to serious compliance issues, including civil penalties and employee disputes. Let’s break down what the law says, what you need to do, and how to protect your business.
Overview of the Pay Stub Protection Act (HB 106)
The Pay Stub Protection Act, passed unanimously by the Ohio General Assembly and signed into law by Governor Mike DeWine, aims to increase payroll transparency for employees.
What Is Required on Pay Stubs?
Effective April 9, 2025, every pay stub issued to Ohio employees must include the following information:
- Employee’s name
- Employer’s name, address, and telephone number
- Dates of the pay period
- Number of hours worked
- Pay rate(s)
- Gross wages
- Itemized deductions
- Net wages paid
This applies regardless of whether pay is issued via physical check, direct deposit, or electronically.
The law is codified in Ohio Revised Code § 4113.89, a new section added under House Bill 106.
Why the Law Was Enacted
According to the Ohio Department of Commerce, the legislation was created in response to growing concerns about wage transparency. In recent years, workers have reported difficulties verifying correct compensation or identifying unlawful deductions. By mandating detailed pay stubs, the state seeks to reduce wage theft and promote fair labor practices.
Ohio joins more than 20 other states, including California, New York, and Illinois, that already have similar pay stub laws in place. The Ohio Department of Commerce emphasized that this change enhances both employee protections and employer accountability.
What This Means for Ohio Employers
Increased Administrative Requirements
If you operate a small or mid-sized business, you’ll need to evaluate your current payroll system to ensure it can generate pay stubs that meet the new requirements. Many third-party payroll providers, like ADP and Paychex, already offer this functionality, but internal systems may need updates.
Potential Liability for Noncompliance
Although the law does not currently establish criminal penalties, employers who fail to provide compliant pay stubs may face:
- Civil liability through wage and hour lawsuits
- Fines from regulatory agencies
- Reputational damage and loss of employee trust
Keep in mind, under the Fair Labor Standards Act (FLSA) and similar state-level wage laws, improper wage documentation can already be used as evidence in wage theft claims. This new law strengthens the basis for such claims in Ohio.
Common Payroll Compliance Pitfalls to Avoid
Not Tracking Hours Accurately
If your payroll system does not track hours accurately — especially for non-exempt (hourly) workers — you’ll risk errors in reported work time and wage calculation.
Implementation Timeline and Best Practices
Effective Date
- The law takes effect April 9, 2025.
- Employers should begin updating payroll practices now to ensure full compliance.
Steps to Take
- Review Your Payroll System
Ensure your system or vendor can generate pay stubs with the required information. - Train HR and Payroll Staff
Your staff must understand the law and how to apply it consistently. - Audit Pay Stubs Before April 9
Conduct a mock run of pay stubs and confirm that each field is correctly populated. - Consult with Legal Counsel
A business attorney can review your compliance practices and reduce legal risks.
Ohio’s new Pay Stub Protection Act is a major development for employers statewide. Small and mid-sized business owners must prepare now to avoid costly compliance failures. By updating payroll systems, educating your staff, and seeking legal guidance, you can ensure a smooth transition before the April 9, 2025, deadline.
Is your payroll system ready for Ohio’s new pay stub rules?
How Gertsburg Licata Can Help
Our firm regularly advises employers on wage and hour compliance, payroll audits, and HR risk management. We help businesses across Ohio implement policies that prevent litigation and align with both state and federal employment laws. If you’re unsure whether your current payroll process meets the new requirements, now is the time to act. Contact us at (216) 573-6000 or [email protected] to be connected to a Labor & Employment attorney.
Sources:
Ohio Department of Commerce. New Pay Stub Requirements for Employers
Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal advice. It does not establish an attorney-client relationship, and any reliance on the information contained herein is done at your own risk. For specific legal guidance tailored to your business and jurisdiction, it is recommended to consult with a qualified attorney who can provide professional advice based on your unique circumstances.
