In 2019, the Fair Work Ombudsman found that 17 Australian-based Subway franchises had underpaid workers.[130] The lengthy investigation by the Ombudsman specifically found that franchises failed to pay the employees minimum wages, casual loadings, holiday and overtime rates, and did not issue proper pay slips or keep proper employment records.[130] The investigation resulted in over $81,000 being recovered in unpaid wages for over 160 employees.[130] Subway responded by introducing a rolling audit of franchisee employment records and commented that franchise agreements could be terminated if franchisees failed to meet Australian workplace laws and Subway's internal standards of operation.[130]