If you suspect an employee made a personal or otherwise unauthorized purchase on a company card, preserve the records, check the policy and account terms, and give the employee a chance to explain before deciding what happened. If misuse is substantiated, apply a consistent response. Do not automatically deduct the amount from wages or demand cash repayment: federal and state wage rules, the card agreement, and the facts can all affect what recovery is lawful.
Start with the transaction record, not an assumption
A purchase that looks personal may be an intentional misuse, but it could also be a mistaken merchant charge, a legitimate expense with incomplete documentation, a coding error, or a transaction on a shared card. Treat the first report as an allegation to assess, not a final finding. Keep the review separate from the process for disputing a charge made by an outside person without authorization.
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Preserve the original transaction information and relevant records before making changes. For each questioned charge, collect what is available:
- The card statement or transaction export, including date, amount, merchant, and any transaction details shown by the issuer.
- An itemized receipt, or a record that a receipt was requested but not provided.
- The expense report, stated business purpose, project or travel details, and any approval or exception.
- The card agreement, applicable approval limits, and the version of the written card policy that was in force on the transaction date.
- Relevant communications and a record of who reviewed the matter, when they did so, and what records they considered.
Keep the source records intact. If an accounting entry or report needs correction, preserve an auditable record of the change rather than overwriting the original. This is sound record-handling practice; there is no single government-prescribed investigation checklist for every private employer.
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Check the rules and hear the employee’s explanation
Compare the charge with the policy, card agreement, approval limits, and the business purpose claimed for it. A clear written policy helps establish which uses were allowed, what documentation was expected, and what consequences could follow. A Texas Workforce Commission sample policy is an example of how an employer can describe permitted uses and possible discipline, not a nationwide legal rule.
Ask the employee for a factual explanation and supporting context, including a receipt if one exists. Give a reasonable opportunity to respond before making a finding. The point is to test the available evidence, not to require the employee to prove guilt or innocence through a particular form that the policy never required.
Classify the issue as carefully as the evidence allows:
- Possible outside fraud: The employee says they did not make or authorize the transaction. Use the issuer’s process for reporting and disputing an unauthorized transaction promptly; deadlines and procedures vary by issuer and account.
- Possible mistake or coding error: The charge may have been made in error, or a legitimate business expense may have been entered under the wrong category. Check receipts, merchant details, and transaction context.
- Unsubstantiated business expense: The employee identifies a business purpose but has not supplied the documentation required by the applicable policy or expense process. Determine whether the documentation can still be obtained.
- Possible intentional personal use: The records and explanation indicate a personal purchase or another use prohibited by the applicable rules. Record the evidence and any material uncertainty before deciding on consequences.
The IRS accountable-plan rules require employees to substantiate allowable business expenses and return excess advances within a reasonable period. Those requirements make records important, but a missing receipt alone does not establish that a charge was intentional personal spending.
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Secure the account and route external disputes correctly
If more charges are possible, use the company’s controls and the issuer’s account terms to suspend or restrict access as appropriate. Consider the scope of the risk: a temporary restriction on one card may be enough, while a broader access change may be warranted if there is evidence of continuing misuse. Record when access changed and who authorized it.
When the employee disputes having made a charge, do not treat an internal employment review as a substitute for the issuer’s dispute procedure. The company or account administrator should follow the account’s reporting process promptly and retain the case number and communications. The available federal statute, 15 U.S.C. § 1645, limits an employer’s or issuer’s ability to impose employee liability for unauthorized use of a business credit card, subject to the limits applicable to unauthorized use. That rule is not the same as deciding whether an employee violated an internal policy or whether a separate repayment claim exists. Review the actual account terms and facts before asserting liability.
Choose a proportionate response based on evidence and consistency
If the evidence supports misuse, possible employment responses include coaching, a written warning, revoking card access, further discipline, or termination. The right response depends on the written policy, seriousness, circumstances, and applicable law. The Texas Workforce Commission sample says misuse may lead to discipline up to termination depending on severity and repetition; it illustrates one policy approach, not a required outcome for all employers.
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| Situation supported by the review | Possible response | Important check |
|---|---|---|
| One-time error or legitimate expense with a documentation gap | Correct coding, seek missing substantiation, or coach on the process | Does the policy permit the expense, and can records still support it? |
| Policy violation with uncertain intent or limited scope | Restrict card access, clarify expectations, or use proportionate discipline | Were the rules clear and applied similarly in comparable cases? |
| Substantiated intentional or repeated misuse | Consider stronger discipline, up to termination where policy and law permit | Does the evidence support the finding, and is the proposed action consistent? |
| Employee denies making the transaction | Use the issuer’s external-dispute process and separately assess any workplace issue | Do not presume that an outside unauthorized charge is employee misconduct. |
These are decision aids, not a mandatory discipline scale. If the amount is significant, the evidence is disputed, or a law-enforcement referral is being considered, consult employment counsel about the relevant facts and local law.
Do not treat repayment as an automatic payroll deduction
Do not simply subtract the alleged amount from the next paycheck or final pay. A signed policy acknowledgment or deduction form does not, by itself, establish that a wage deduction is lawful. Before seeking repayment, identify who is responsible under the account agreement, what the employee agreed to, how the charge was classified, and which wage-payment rules apply in the employee’s state.
The U.S. Department of Labor’s Wage and Hour Division explains in Fact Sheet #16, revised July 2009, that an employer generally may not shift costs primarily for its own benefit to an employee if doing so reduces pay below the federal minimum wage or cuts into required overtime. Its examples include damage to employer property and theft. The fact sheet also says an employer cannot evade the FLSA limits by demanding cash reimbursement instead of making a payroll deduction. This is general federal guidance; application depends on the facts, and state wage-payment laws may impose stricter restrictions.
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Get state-specific legal advice before choosing a repayment method, especially for final wages, disputed liability, or an employee whose pay includes overtime. Do not assume that describing repayment as voluntary or collecting it outside payroll resolves the legal issue. The Texas Workforce Commission sample includes a deduction agreement as an example of policy language, but it does not make that form effective in every state or circumstance.
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Take extra care with exempt salaried employees
A deduction from an exempt employee’s salary can raise a separate salary-basis problem. Under 29 CFR § 541.603, a practice of improper deductions can jeopardize the exemption for affected employees; a communicated written policy and a complaint process are relevant to the regulation’s analysis. Avoid informal salary deductions as punishment for alleged card misuse. Have counsel or payroll specialists review any proposed deduction against the regulation and applicable state law.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Coordinate accounting and tax treatment
For an IRS accountable plan, the expense must be an allowable business expense, the employee must substantiate it within a reasonable period, and excess advances must be returned within a reasonable period. Amounts paid under an accountable plan are not wages subject to federal income-tax withholding, Social Security, Medicare, and FUTA taxes, as described in IRS Publication 15 (2026).
That general treatment does not settle the payroll or tax treatment of every personal, unsupported, or disputed card charge. Keep the transaction and repayment records, and ask payroll or a tax professional how to record the actual facts. Do not reclassify a personal purchase as a business expense merely to simplify the books.
Know what card liability and credit reporting do—and do not—mean
Three questions are often conflated: whether a charge violated workplace policy, whether the employee is legally responsible to repay the employer or issuer, and whether a corporate-card history can appear in an individual’s consumer report. They are not interchangeable. Section 1645 of Title 15 addresses employee liability for unauthorized use of a business credit card; it does not by itself decide every internal employment or reimbursement dispute involving an employee’s use of an authorized card.
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The Federal Trade Commission’s October 27, 1998 Tabler advisory opinion describes consumer-report treatment as depending on whether the individual is legally responsible for payment under the account terms or otherwise. A company-card delinquency is therefore not automatically the employee’s personal credit obligation. Check the agreement and current law before making a claim about an employee’s personal liability or credit history.
If an employer obtains a consumer report from a reporting company to make an employment decision, EEOC and FTC guidance describes Fair Credit Reporting Act steps such as a standalone written notice and authorization, along with other requirements. That guidance concerns consumer reports; reviewing the employer’s own card statements and internal records is not automatically the same thing as obtaining a consumer report. Employers must also avoid discriminatory use of information.
Document the closeout
Once the review is complete, keep a concise record of the issue, the policy version applied, the evidence considered, the employee’s explanation, the finding, and the reason for the action taken. Record any card-access change, issuer dispute, accounting correction, or repayment arrangement separately so later reviewers can distinguish those steps from the employment decision.
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