A wafer-level manufacturing method produces stress compensated x-y gimbaled comb-driven MEMS mirror arrays using two SOI wafers and a single carrier wafer. MEMS structures such as comb drives, springs, and optical surfaces are formed by processing front substrate layer surfaces of the SOI wafers, bonding together the processed surfaces, and removing the unprocessed SOI layers to expose second surfaces of the front substrate layers for further wafer-level processing. The bonded SOI wafers are mounted to a surface of the carrier wafer that has been separately processed. Processing wafer surfaces may include formation of a stress compensation layer to counteract physical effects of MEMS mirrors. The method may form multi-layered conductive spring structures for the mirrors, each spring having a first conducting layer for energizing a comb drive, a second conducting layer imparting a restoring force, and an insulating layer between the first and second conducting layers.