
A new payroll platform does not fix your payroll system.
The platform is one part of it. The rest is your data, your award and agreement interpretation, the processes around the software and the people who run them.
Most non-compliance starts in that second group rather than in the technology. It moves across with your data, and it keeps accruing. Claims under the Fair Work Act reach back six years.
Here is what to check, and when.
Most migrations start for one of four reasons.
Three of those four put the attention on the technology. The data, the interpretation and the processes then get less scrutiny during the project, even though they are often what is driving the change.
Configuration defects run for years without being noticed.
One of Australia’s largest resources companies disclosed in 2023 that leave had been incorrectly deducted on public holidays since 2010. The correction came to about $430 million across 28,500 current and former employees.
A Group of Eight university disclosed a design flaw in its timesheet system in 2024. Timesheets stayed visible for only two weeks, so unprocessed ones never surfaced. It ran for 11 years and covered 2,290 current and former staff.
Fair Work Ombudsman enforceable undertakings name the same two causes over and over: governance and the payroll system itself. A tier-two public university paid $21.4 million across 10,443 employees. A dual-sector regional university paid over $4 million, attributed to a decentralised payroll system and improper configuration.
Your pay codes migrate. The record of how they were read does not.
What gets lost:
The people who held that knowledge have usually left by the time anyone needs it. Section 535 of the Fair Work Act still requires you to keep employee records for seven years, and section 544 lets a claim reach back six.
Termination payments, long service leave and back pay often keep their legacy rules.
The same manual steps then run on new data, and they rarely get tested.
One state health department shows what the last flag produces. Its project board revised the defect severity definitions in July 2009, then changed the exit criteria for the final round of testing. The commission of inquiry that followed called the result a catastrophic failure.
Not midway through, when the load templates are due and the timeline is already fixed.
Map every award, agreement and contract that applies, and how your organisation interprets each one. Every pay record then gets measured against a single standard.
This is where cohorts sitting under the wrong award show up, along with pay rises written into an agreement and never paid through.
Capture the reasoning behind your configuration while the people who hold it are still in the business.
Check and record four things:
Save the results somewhere you can find them. Anyone reconstructing the past later starts from that record instead of from nothing.
That same health department tested a parallel pay run across ten per cent of employees, eight months before go-live. Its software vendor had recommended a full parallel run and the project board declined it, because of the size of the task.
A sample confirms the common cases. Errors concentrate in the uncommon ones: broken shifts, sleepovers, overtime, allowances and terminations.
Settle four questions before testing finishes.
Since 27 February 2024, section 557A means a serious contravention of the Fair Work Act needs only recklessness. It no longer has to be knowing and systematic.
You will find entitlements you cannot test, because the data was never captured.
There are three defensible ways to handle it.
Section 557C puts the burden on you to disprove a claim where the records were not kept. The Fair Work Ombudsman expects employees to get the benefit of the doubt where records are deficient. Its remediation guidance treats six years as a minimum review period rather than a limit.
Termination payments, long service leave and back pay run on new data through old rules. Check them against real cases inside the first three months.
Each annual wage review, each agreement expiry and each acquisition changes what correct looks like. Put a date against each one.
Put data quality and change control in a position description, with a name against it.
Errors that reach production stop being a project issue. They become a liability that accrues every pay run until somebody finds them.
Payroll Experts runs payroll audits, remediation, system implementations and processing support for about 230 organisations across healthcare, aged care, government, education, retail and mining.
Sources: Fair Work Act 2009, sections 535, 544, 557A and 557C. Fair Work Ombudsman, Payroll Remediation Program Guide (April 2025) and published enforceable undertakings. Company and university disclosures. State audit office and commission of inquiry reports into a public health payroll replacement. Organisations are not named.

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