On December 3, the Shanghai Federation of Trade Unions released the 2025 Public Compliance Advisory on Wage Payment, reminding all employers across the city of their legal obligations regarding salary and payroll management. The notice emphasizes that timely and full payment of wages is a basic labor right and a cornerstone of social fairness and stability.
The advisory highlights five key compliance areas that employers must follow.
1. Ensure Timely and Full Payment of Wages
Employers must pay wages in full, on time, and in monetary form, strictly following employment contracts and national regulations. Clawbacks, unauthorized deductions, delayed payments, or replacing wages with goods or securities are strictly prohibited.
Before public holidays and rest days, wages must be paid in advance. The notice also stresses that dispatched workers and outsourced labor must receive equal protection in wage payments.
2. Clarify Wage Rules in Contracts and Agreements
Employers should sign written labor contracts with employees specifying wage standards, payment methods, and pay cycles.
For platform-based workers who do not fully meet the criteria for an employment relationship, platform companies must sign written agreements covering workload standards, commission rates, piece-rate pricing, pay cycles, and performance assessment rules to ensure clarity and transparency.
3. Implement Minimum Wage Standards
Employees who provide normal labor must be paid no less than the applicable local minimum wage.
For “new forms of employment” workers (e.g., gig workers, platform-delivery workers) who fall under platform management but do not fully establish labor relations, the hourly minimum wage standard of the actual working location applies.
4. Follow Proper Procedures When Establishing Wage-Related Rules
Any company regulations involving salary, payroll calculation, or matters affecting employee interests must be discussed through the workers’ congress or by all employees.
Enterprises must negotiate with unions or worker representatives to finalize wage-related rules and conduct wage collective bargaining to ensure employee participation and transparency.
5. Strengthen Compliance in Construction and Project-Based Work
General contractors in the construction sector must:
• Open a dedicated wage payment account for migrant workers
• Implement real-name labor management
• Ensure that project owners pay labor costs into the account on time (at least once per month)
• Provide payment guarantees when required
These measures aim to address long-standing wage arrears risks in the construction sector.
Ongoing Enforcement in Shanghai
The Shanghai Federation of Trade Unions will continue wage enforcement through:
• Public legal education
• Compliance inspections
• Dispute mediation
• Legal aid and worker support
Employees may report wage violations by calling Shanghai’s worker hotline 12351.
Source: Shanghai Federation of Trade Unions Official Notice
