Employer Compliance Checklist-One Big Beautiful Bill (OBBB)
A concise, action-packed checklist for payroll, HR, and finance teams.
1) Payroll & Reporting
- Update payroll software to track qualified overtime and tip income separately.
- Ensure W-2 and 941 forms reflect new reporting categories once IRS guidance is issued.
- Review pay policies to confirm overtime calculations comply with FLSA and OBBB definitions.
2) Benefits & Employee Plans
- Review health and benefit plan documents for OBBB changes (e.g., HDHP telehealth flexibility).
- Update employee handbooks, SPDs, and open-enrollment materials.
- Verify eligibility and administration for dependent care FSA and student-loan repayment benefits.
- Communicate updates clearly before the next enrollment cycle.
3) Tax Credits & Incentives
- Evaluate eligibility for the expanded employer childcare credit.
- Confirm qualification for the Paid Family & Medical Leave (PFML) tax credit.
- Document policies and payments tied to credits; coordinate with your tax advisor.
4) Workforce Eligibility & Documentation
- Conduct an internal I-9 audit and resolve missing or expired documentation.
- Use the current Form I-9 (Rev. 08/01/23) and ensure proper e-verification procedures.
- Train managers on immigration compliance and audit response protocols.
5) Policy & Training Updates
- Refresh the employee handbook and internal policies to reflect OBBB rules.
- Schedule training for HR and payroll staff on new requirements.
- Update job postings, onboarding materials, and compliance acknowledgments.
- Communicate changes via memo, town hall, or intranet.
6) Ongoing Monitoring
- Subscribe to IRS and DOL update alerts for upcoming guidance.
- Set quarterly compliance reviews and maintain a central OBBB documentation file.
- Review vendor contracts (benefits administrators, childcare providers, etc.) for compliance.
Key Effective Dates
- January 1, 2025: Most payroll & benefit provisions begin.
- December 31, 2025: Enhanced childcare credit and related incentives start applying.
- 2025-2028: Temporary payroll deductions for qualified overtime apply.
Pro Tip: Form a cross-functional OBBB Compliance Team - HR, payroll, finance, and legal - to manage timelines and documentation.
© 2025 Employer Compliance Guide - OBBB. This content is provided for general informational purposes and is not legal or tax advice.

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