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What “Reasonable Steps” Really Mean in 2026: How California Employers Reduce PAGA and Employment Litigation Exposure

As California employers move through 2026, one thing is clear: employment litigation—and PAGA litigation in particular—is not slowing down.

Despite the highly publicized 2024 PAGA reforms, 2025 became the largest year yet for PAGA LWDA filings. That reality has…

For most California employers, employee time and pay data has historically been treated as a legal obligation—something you keep because the law requires it, not because it creates value.

That mindset needs to change in 2026.

After years of defending employers in wage-and-hour class actions and PAGA cases, I have seen firsthand how employee data…