The Law

Understanding Oregon SB 426

Signed June 9, 2025. Effective January 1, 2026. The most significant change to construction wage liability in Oregon history.

What the law does

SB 426 extends wage liability up the contracting chain on Oregon construction projects. Five provisions matter most:

Joint and several liability

Project owners and direct contractors are equally liable for unpaid wages owed to workers of any subcontractor at any tier — even if the GC paid the sub in full.

Indemnification prohibited

Contracts cannot waive or indemnify away this liability. Traditional hold-harmless clauses are legally unenforceable for wage claims. You cannot paper over this risk.

Record request rights

GCs and owners can request certified payroll records and a 5-year wage violation affidavit from any subcontractor. The law grants the right — but no mechanism to compel delivery or verify accuracy.

Civil enforcement

Unrepresented workers, third-party advocates, or the Oregon Attorney General can bring civil action to recover unpaid wages, penalty wages (up to 8×), interest, and attorneys' fees.

Limited exemptions

Primary residence projects and developments with 5 or fewer residential/commercial units on a single tract are excluded. Public agencies are not "owners" under the liability provisions. Everything else is in scope.

The core insight

SB 426 doesn't just create a payroll problem — it creates a documentation and supply-chain visibility problem. GCs must prove they acted with due diligence across every tier. No existing tool addresses this end-to-end.

Who bears the risk

PartyExposureNotes
General ContractorsFull joint/several liability for all subs and sub-subsHighest urgency — they manage the most sub-tiers
Project Owners / DevelopersLiable alongside the GCExposure on every commercial project they commission
Prime SubcontractorsLiable for their own sub-subsExposed whenever they use lower-tier subs
Property Investors / REITsLiable as "owners" above the exemption thresholdMany don't realize they're exposed on tenant improvement work

Why documentation is the only defense

Even if you paid every sub correctly, you face liability if any sub-tier worker wasn't paid. The only way to limit exposure is to collect verified certified payroll records before each payment cycle and preserve them as an audit trail — proof that you exercised reasonable diligence.

EXPOSURE

The stakes are material

One mid-size project — 50 workers at $50/hr underpaid by 10% for a year — produces $520,000 in unpaid wages before penalties. A GC with 5 active projects carries potential multi-million-dollar exposure at any moment.

GAP

The law gives rights, not tools

You can request records — but nothing compels subs to deliver them, verifies their accuracy, or proves you asked. Email threads and spreadsheets won't survive discovery.

DEFENSE

Due diligence, documented

A timestamped record of every request, submission, verification, and sign-off — assembled into a signed compliance package — is what "reasonable diligence" looks like to a court.

The law is in effect. The window to get compliant is now.

Every pay period since January 1, 2026 is either documented or it isn't. Start building your audit trail today.

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