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Indicator 3.8.5
by Contact on 8 October 2026
Requirement
The UoC shall pay wages in full directly to employees in legal tender or into a bank account in their name at regular intervals, at least monthly. Wages shall not be delayed, deferred or in any way withheld. **
How Do I Interpret This Requirement?
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Legal tender does not include:
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notes which banks no longer exchange
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notes which are not accepted (for example, too small)
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currency which is unusable due to inflation
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in-kind benefits (food, housing, etc) of any kind.
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There are situations where withholding salary, property or benefits are legally required, and so allowed under this indicator. For example:
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salary withholdings, as required by the government. For example, part of a salary is sometimes withheld by a government for:
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statutory pensions
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health insurance
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taxes.
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a government can sometimes require the withholding of salary to pay overdue child-care support costs to another parent or pay overdue taxes
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salary deductions, as defined in a contract or collective bargaining agreement, that are agreed by both parties. For example, an agreed voluntary deduction for housing costs could be allowable.
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bonuses, which are considered optional and additional to the agreed salary and benefits. However, if clearly defined performance targets related to a bonus payment, as defined in a contract have been achieved, then the bonus cannot be withheld.
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Evidence of Implementation
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employee contracts
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payslips
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payment transactions.
Auditors Should Confirm
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direct, regular, and accurate payment to employees through records review and interviews with employees and management;
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if there are any instances when wages were delayed, deferred or withheld in the past and why;
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employees understand the process for raising grievances if wages are delayed or inaccurate;
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when foreign migrant employees are employed, apart from legally required deductions, no other deductions shall be made from their wages before payment, for example:
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recruitment or agency fees
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cost of airfare
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employment visas
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any fees or costs incurred in the recruitment process for employees to secure employment or placement, regardless of the manner, timing or location of their imposition or collection.
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Useful Resources
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General principles and operational guidelines for fair recruitment and definition of recruitment fees and related costs: <https://www.ilo.org/sites/default/files/wcmsp5/groups/public/@ed_protect/@protrav/@migrant/documents/publication/wcms_536755.pdf>
