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FWOFair Work Ombudsman · 30 March 2026

Fair Work Ombudsman

Citation: FWO-2026-03-31-angel-cn-penalty-media-release

At a glance

Penalty
$17,502
Employees affected
1

What happened

Stuart Angel, the former operator of Angel Smash Worx in Gosford, NSW, has been penalised $17,502 by the Federal Circuit and Family Court. This followed a Fair Work Ombudsman investigation into breaches of pay slip laws and failure to comply with a Compliance Notice. Mr. Angel employed a worker from August 2018 to April 2022, including a period as an adult apprentice. The worker raised concerns about underpayment of minimum wages, annual leave entitlements, and training costs.

What was decided

The Federal Circuit and Family Court imposed penalties of $17,502 on Stuart Angel for breaching pay slip laws and failing to comply with a Compliance Notice. The court ordered Mr. Angel to calculate and back-pay the worker's entitlements, including interest and superannuation. Judge Papadopoulos found Mr. Angel’s failure to provide pay slips prevented the worker from monitoring their wages. The court emphasized the importance of complying with Compliance Notices and providing accurate pay slips.

What it means for employers

Employers must comply with pay slip laws and respond appropriately to Compliance Notices issued by the Fair Work Ombudsman. Failure to do so can result in significant penalties. Providing accurate pay slips is crucial for transparency and allows employees to monitor their pay.

What it means for employees

Employees should contact the Fair Work Ombudsman for free assistance if they have concerns about their pay or entitlements. Pay slips provide essential information about wages and entitlements, and employees should review them carefully.

underpaymentpenalty-ratesgeneral-protectionspay-slipscompliance-noticemodern-award-variationapprenticeship

Every statement above is drawn from the published decision. Read the original here:

https://www.fairwork.gov.au/newsroom/media-releases/2026-media-releases/march-2026/20260331-angel-cn-penalty-media-release

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This summary was drafted by AI from the published decision and reviewed before publishing. It is general information, not legal advice. For your specific situation, speak to the Fair Work Ombudsman (13 13 94) or a qualified lawyer. About these summaries & corrections →

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