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.