We checked 24 claims in this time-clock rounding research against federal regulations, California and Oregon case law, California court rules, and federal recordkeeping rules. All 24 verified; no unsupported, outdated, or unresolved claims remain.
This research is written for an employer deciding whether to keep a rounding policy. The fact check focuses on the claims that employer would act on: what federal law permits, why neutrality has to be proven with real data, why California and Oregon are higher risk, why meal-period rounding is different, why raw punches matter, and why exact-time pay is usually the cleaner operational choice.
Ship verdict: the research can ship under this fact-check. Recheck Camp v. Home Depot and Woodworth v. Loma Linda whenever the California Supreme Court updates either docket.
5 claims
Federal law permits rounding to the nearest 5 minutes, one-tenth of an hour, or quarter hour
§785.48(b) names nearest 5 minutes, one-tenth of an hour, and quarter hour.
Federal rounding is allowed only if it does not underpay employees over time
The regulation requires the practice not to result, over time, in failure to compensate employees properly for all time worked.
Early or late punches may be disregarded only if no work is performed
§785.48(a) permits disregarding early/late time only when employees do not engage in work during the period.
Federal law requires records of hours worked each workday and total hours worked each workweek
§516.2(a)(7) supports the raw-hours recordkeeping point.
Federal payroll records are generally retained three years and supplementary wage computation records two years
The research states the federal floor and notes some states may require more in adjacent content.
2 claims
The 7-minute quarter-hour rule is a convention, not a separate statute
The regulation permits quarter-hour rounding but does not codify the common 7/8 split table.
Rounding is not required by federal law
The regulation accepts certain rounding practices for enforcement purposes; it does not require employers to round.
6 claims
See's Candy adopted the federal neutral-rounding standard for California wage claims
The research correctly says this is the older California rule and explains that later cases narrowed it.
AHMC upheld rounding where the workforce gained time overall
The research uses AHMC only to explain the employer-favorable phase of California rounding law.
Donohue held that rounding cannot be used for California meal periods
Donohue is a California Supreme Court decision and remains binding.
Camp held that when exact time is captured, California employers must pay for all time worked instead of rounded time
The research immediately discloses that California Supreme Court review is pending and that the Court of Appeal decision has persuasive value only during review.
Eisele held that Home Depot's rounding policy was not permitted under Oregon wage law
The research correctly identifies Eisele as a federal district-court decision, not an Oregon Supreme Court decision.
If employer records are inadequate, Mt. Clemens allows proof by just and reasonable inference
The research uses Mt. Clemens for the recordkeeping-risk explanation, not as a rounding-specific case.
1 claim
The California Supreme Court granted review in Camp on February 1, 2023
The linked opinion page notes review granted. Rule 8.1115 explains the persuasive-value status after grant of review.
1 claim
California Rule of Court 8.1115(e)(1) makes a granted-review Court of Appeal opinion persuasive, not binding
The research uses this to avoid overstating Camp while still explaining why employers treat it seriously.
1 claim
Woodworth followed Camp and the California Supreme Court granted review
The research correctly says Woodworth follows the same direction and is pending behind Camp.
1 claim
If Camp is reversed, Donohue still bars California meal-period rounding
Donohue is a final California Supreme Court decision independent of Camp.
5 claims
Exact-time pay is usually the simpler operational choice when exact time is captured
This is a risk-management conclusion drawn from the federal neutrality requirement, exact-time availability, California litigation, and recordkeeping burden. It is correctly framed as "usually," not as a universal legal mandate.
Employers should audit rounding with actual punch data
The regulation's "over a period of time" requirement makes an actual-data audit the practical way to test neutrality.
Employers should preserve raw punches, not only rounded payroll totals
Raw punches are the evidence needed to verify actual time worked and audit rounding.
Multi-state employers often reduce risk by using exact-time pay everywhere
This is an operational conclusion, not a statute. It follows from federal neutrality, California/Oregon state risk, and recordkeeping simplicity.
Employers should get counsel involved before correcting past underpayment discovered in a rounding audit
Past underpayment can trigger overtime, wage-statement, final-pay, and class-action issues depending on the workforce and state.
15 unique sources cited across the report — click to audit any claim directly against its evidence.
Every claim above links to the source we used. Open any source to compare the wording here with the underlying rule, guidance, court opinion, or product behavior.
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