AB 2288
Assemble the policies, training, and audit trail California employers use to show they took all reasonable steps before a PAGA notice arrives.
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Your proof kit is unlocked. Download the PDF, work the checklist below, then turn the file into an audit plan.
01 / Timing windows
AB 2288 updated Labor Code §2699 so timing and documentation can limit recoverable civil penalties. Caps are conditional frameworks, not guaranteed discounts.
Labor Code §2699(g)
Employers who took all reasonable steps to comply with later-identified provisions before a notice or certain records requests may face capped recoverable civil penalties under the statute’s framework.
Labor Code §2699(h)
Within 60 days after notice, all reasonable steps to prospectively comply may limit recoverable civil penalties. Speed and documentation both matter.
All circumstances
Courts and counsel look at employer size, resources, the nature of alleged violations, and whether field practice matched the written program. A checklist alone is not a defense.
02 / What’s in the kit
Unlock the checklist to mark each item and download the PDF. Completing the list does not guarantee a statutory limit. Practice still has to match the paper.
Wage-and-hour handbook versions that match California requirements across the lookback.
Manager sessions, attendance, and materials dated to the periods that matter.
Who reviews exceptions (missed meals, edits, late punches) and how often.
Forensic or internal reviews with findings, owners, and close-out dates.
What changed when gaps appeared: SOP updates, coaching, back pay if owed.
Time, payroll, and wage-statement records held for the PAGA lookback.
The interactive checklist and PDF sit behind a short unlock. That is how we keep the kit current and useful.
Next step
Get the checklist first. After that, we will show the next step for documenting reasonable steps with Easeworks.
Next step
Most employers who unlock this kit still need help assembling records, training trails, and corrective actions before a notice arrives.
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