The WRC held that the employer lawfully deducted training costs from the complainant’s final wages as the repayment obligation was clearly agreed in writing and formed part of the contract of employment.

The Complainant stated that the Respondent unlawfully deducted €2,126 from his final wages in February 2025, contrary to the Payment of Wages Act 1991. He explained that he received an email in advance notifying him of the intended deduction and that he clearly replied stating he did not agree and that such a deduction was not lawful. He asserted that he never gave written consent for the sum to be deducted from his wages at the time the deduction was made. While he accepted that training costs might be repayable, he maintained there was no agreement permitting recovery by way of a direct wage deduction. He further complained that his final payslip was inaccurate, failed to reflect hours worked, and did not clearly identify or explain the deduction. As a result of the deduction, he said he was left without funds for rent or basic living expenses, causing significant stress and hardship. He relied on emails and payslip evidence to support his claim.

The Respondent stated that the Complainant had entered into a clear and binding agreement in relation to specialised training costs. The Respondent explained that the Complainant was sponsored to undertake a Rope Access Level 3 training course on the explicit condition that he would remain employed for a minimum of two years, failing which he would repay 100% of the course costs. This agreement was signed by the Complainant in October 2024 and formed part of his contract of employment. The Respondent submitted that the Complainant left employment before completing the two-year term and therefore triggered the repayment clause. By email dated in February 2025, the Respondent clearly set out how the sum of €2,126 was calculated, comprising €1,250 in course fees and €876 in wages paid during training. The Respondent relied on a subsequent email from the Complainant confirming acceptance of the financial arrangement and contended that the deduction was both lawful and reasonable.

The Adjudicating Officer examined the relevant provisions of the Payment of Wages Act 1991 and considered whether the deduction was authorised under s.5 of the Act. It was found that the Complainant had voluntarily signed a written agreement in October 2024 confirming that sponsorship for training was conditional upon remaining employed for two years, with a clear obligation to repay 100% of the course cost if he left early. The Adjudicator held that this agreement validly amended the contract of employment and therefore satisfied the statutory requirement that a deduction be authorised by a contractual term in force at the time of the deduction. While acknowledging that deducting the full amount in one sum might be viewed as strict, the Adjudicator found it was not harsh or unreasonable in the circumstances. Particularly, given the Complainant’s departure from the jurisdiction and the relatively modest proportion of wages involved. Accordingly, the complaint was found not to be well founded, and the deduction was deemed lawful.

Employers who fund employee training should ensure that all repayment obligations are clearly documented in writing and expressly incorporated into the contract of employment. Any agreement to repay training costs should specify the circumstances in which repayment arises, the amount recoverable, and the method of recovery. Having the employee sign such an agreement in advance is crucial, as it provides contractual authority for any future deduction. When making deductions from wages, employers should strictly comply with the Payment of Wages Act 1991 by ensuring the deduction is authorised by statute, contract, or by prior written consent. Deductions should be clearly explained in advance and accurately reflected on payslips, including the nature and amount of the deduction. Transparency reduces the risk of disputes and strengthens the employer’s position if a complaint arises. Finally, employers should consider proportionality when recovering sums owed, particularly from final wages. While a single deduction may be lawful, employers should assess whether alternative arrangements such as instalments are appropriate.   

The full case can be found here.