Oregon Enacts Law Requiring Employers to Explain Payroll Codes

Oregon has added another detailed payroll documentation requirement for employers. Oregon law has long required employers to provide employees with detailed written wage statements, including pay rates, pay basis (e.g., hourly, salary, piece, or commission), gross and net wages, itemized deductions, and nonexempt employees' regular and overtime hours worked and corresponding pay.

On May 28, Oregon Gov. Tina Kotek signed into law Oregon Senate Bill 906, which will take effect Jan. 1. The law amends Oregon Revised Statutes (ORS) 652.610 to require employers to disclose to employees significantly more information about their payroll at the time of hire. 

Written Payroll Code Disclosure

Specifically, employers will be required to provide a written explanation of the following:

• The earnings and deductions under ORS 652.610(1), some of which are summarized in the first paragraph of this article.
• All payroll codes used for pay rates and deductions, along with a detailed description or definition of each code.
• A comprehensive list of all pay rates that employees may be eligible for, all benefits deductions and contributions, and every type of deduction that may apply.
• The purpose of deductions that may be made during a regular pay period.
• Allowances, if any, claimed as part of the minimum wage.
• Employer-provided benefits that may appear on the itemized statements as contributions and deductions.

Employers are required to update this information by Jan. 1 of each year. 

Enforcement

The commissioner of Oregon’s Bureau of Labor and Industries (BOLI) may issue a $500 civil penalty against any person who violates the amended statute or any rule BOLI later adopts under the amended statute. Employees do not have a private right of action to bring a civil action for statutory violations.  

Model Guidance

BOLI will issue a model written guidance document (in English, Spanish, and potentially other languages) that includes commonly used statewide deductions that employers may use and customize to satisfy the requirements of this law. This model guidance document will be critical to determine the level of detail expected for each pay and deduction code, as currently the only statutory guidance on the level of detail is the note that descriptions “need not be written in complete sentences.”

Disclosure Delivery

Employers can comply with these requirements by making the information available to employees in a location easily accessible to them, such as email, a document posted on an intranet website, or a document posted at a central work location. Employers may want to consider including such information as part of the employee’s onboarding packet and regularly updating the information by Jan. 1 of each year. 

Conclusion and Next Steps

While waiting for the model guidance to be issued, employers can get started on this project by pulling a report from their payroll department or payroll provider that lists all pay codes and deductions codes. Often, these reports will have a short description of each pay and deduction code, which can be a great starting point for building out Oregon’s required payroll code disclosure. Multiple departments may need to be involved to fully describe each payroll code, so beginning this project now is advisable to be prepared for Jan. 1, 2026. 

Justin D. Brown is an attorney with Littler in San Jose, Calif. Paul E. Cirner and Gilbert A. Cotto-Lazo are attorneys with Littler in Portland, Ore. © 2025 Littler. All rights reserved. Reposted with permission.