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Hire someone in Australia and you have one working day to get them a payslip. Miss it and you're looking at AUD $19,800 in fines — per violation.
Meanwhile, in Texas, there's no state law requiring pay stubs at all.
If you employ people in more than one country — or even more than one US state — you're dealing with a patchwork of rules that don't always make intuitive sense.
Quick Reference
| Country | Required? | Electronic OK? | Key Penalty |
|---|---|---|---|
| US | State-dependent | Most states | CA: $50–100/violation |
| UK | Yes, all workers | Yes | Tribunal: 13 weeks' deductions |
| Germany | Yes | With consent | Labour court claims |
| France | Yes | Employee can opt out | €450/payslip |
| Australia | Within 1 day | Yes | AUD $19,800/violation |
| Japan | Yes | Yes | Labour Standards warnings |
| Singapore | Yes | Yes | SGD $200/offence |
| Spain | Yes, prescribed format | Yes | Ministry of Labour sanctions |
North America
United States — 50 States, 50 Sets of Rules
No federal law requires pay stubs. The FLSA requires you to keep records, but doesn't say you have to share them in any particular format.
States fill that gap — inconsistently.
California is the strictest. Labor Code §226 demands nine specific data points. Miss any and the penalty is $50 first, $100 after — per employee, per pay period. For 100 employees, a systemic error racks up five-figure fines in a single quarter.
New York requires hours, rates, deductions, and allowances with every payment.
Texas, Alabama, and Mississippi? No state requirement at all.
The practical advice: provide detailed pay stubs everywhere, regardless of legal requirements. The cost of generating them is trivial compared to defending yourself without them.
Canada
Each province sets its own rules. Ontario requires pay statements with each payment. British Columbia mandates hours, rates, overtime, and deductions. Quebec requires pay stubs in French.
Europe
United Kingdom
Since April 2019, payslip requirements extend to all workers — not just employees. This includes agency workers and casual staff.
Required fields: gross pay, variable deductions with amounts, net pay, and hours worked for time-based pay.
The penalty for non-compliance? An Employment Tribunal can order back-payment of any "unnotified deductions" for up to 13 weeks. If you've been deducting pension contributions without showing them — that's a nasty surprise.
Germany
German payslips are dense by design. The Entgeltabrechnung shows:
- Income tax (Lohnsteuer)
- Church tax (Kirchensteuer) if applicable
- Solidarity surcharge
- Four social insurance contributions — health, pension, unemployment, nursing care
- Both employee and employer portions
Employees see the full cost of their employment. For employers, getting any single line wrong is immediately visible.
France
The bulletin de paie is an outlier. Even after a 2018 simplification reform, over 40 mandatory fields remain. The reform grouped similar contributions to look cleaner, but the underlying data requirements didn't change.
And here's the catch: employees can opt out of electronic delivery at any time, forcing the employer back to paper.
Spain
The nómina must follow a specific format from the Ministry of Labour. You can't wing it with a generic template — the prescribed structure separates employer data, employee data, earnings, and deductions in a specific order.
Spain also uses 14 monthly payments per year — two extra pagas extraordinarias in June and December.
Asia-Pacific
Australia
Combines the strictest timing with steepest penalties.
Payslips within one working day of payment. Must include the employer's ABN, gross/net amounts, all loadings, superannuation contributions (currently 11.5%), and authorised deductions.
The Fair Work Ombudsman actively audits businesses. Penalties for individuals: up to AUD $19,800 per contravention. For companies: up to $99,000.
Japan
The Labour Standards Act requires wage statements showing income tax, residence tax, and all social insurance deductions.
Overtime has specific rules that affect payslip formatting:
| Type | Premium | Example |
|---|---|---|
| Regular overtime | +25% | ¥2,500 base → ¥3,125 |
| Late-night work (10 PM–5 AM) | +25% | Stacks with overtime |
| Holiday work | +35% | ¥2,500 → ¥3,375 |
| Late-night overtime | +50% | Both premiums combined |
Each premium must be shown separately on the payslip.
Singapore
Itemised pay slips required since 2016, with particular attention to CPF (Central Provident Fund) contributions. Rates vary by age group and residency status — citizens, permanent residents, and foreign workers all have different schedules.
Singapore notably does not withhold income tax from paychecks. Employees file and pay taxes annually. But employers must still submit earnings data to IRAS each year.
What This Means in Practice
Operating in a single country? Learn the rules once, set up your template, maintain it as regulations update.
Operating across borders? A UK employee's payslip looks nothing like a French one. Australian timing is stricter than anywhere in Europe. US requirements depend on which state your employees are in.
CleverSlip handles this with country-specific templates — select the country, and the payslip includes every field that jurisdiction requires.
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