February 27, 2020

Martin Mucci
President and Chief Executive Officer
Paychex, Inc.
911 Panorama Trail South
Rochester, New York 14625-2396

       Re: Paychex, Inc.
           Form 10-K for the Fiscal Year Ended May 31, 2019
           Filed July 24, 2019
           File No. 000-11330

Dear Mr. Mucci:

       We have reviewed your filing and have the following comments. In some of
our
comments, we may ask you to provide us with information so we may better
understand your
disclosure.

       Please respond to these comments within ten business days by providing
the requested
information or advise us as soon as possible when you will respond. If you do
not believe our
comments apply to your facts and circumstances, please tell us why in your
response.

       After reviewing your response to these comments, we may have additional
comments.

Form 10-K for the Fiscal Year Ended May 31, 2019

Consolidated Financial Statements
Consolidated Statements of Income and Comprehensive Income, page 40

1.    Please tell us and present separately in your financial statements the
material components
      of the operating expenses line item. Refer to Rule 5-03.3 of Regulation
S-X. Please also
      tell us and disclose in an accounting policy footnote the types of
amounts included in
      operating expenses versus selling, general and administrative expenses.
Note B - Service Revenue
Assets Recognized from the Costs to Obtain and Fulfill Contracts, page 55

2.    Please tell us the specific types of incremental costs of obtaining a
contract that you have
      recognized as an asset. Also, tell us separately for each type of
incremental cost how you
      determined the asset recognition criteria in paragraphs 25-1 through 25-3
of ASC 340-40-
      25 were met.
 Martin Mucci
Paychex, Inc.
February 27, 2020
Page 2

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

      You may contact Keira Nakada at (202) 551-3659 or Rufus Decker at (202)
551-
3769 with any questions.



FirstName LastNameMartin Mucci                            Sincerely,
Comapany NamePaychex, Inc.
                                                          Division of
Corporation Finance
February 27, 2020 Page 2                                  Office of Trade &
Services
FirstName LastName