California’s pay reporting deadline, May 14, 2025, is fast approaching. As required by California law, private employers with 100 or more workers must annually submit data on pay, hours worked, and demographics of their employees to the California Civil Rights Department (CRD).
By requiring employers to report pay data annually, California aims to encourage employers to self-assess pay disparities along gendered, racial, and ethnic lines in the workforce and to promote voluntary compliance with equal pay and anti-discrimination laws.
Who Must File
Private employers who meet the following criteria in 2024 must file annual pay reports:
- Directly employed 100 or more full- and part-time employees with at least one based in California.
- Hired 100 or more workers through labor contractors, i.e. a staffing agency, with at least one based in California
Key Reporting Requirements
Employers must submit two reports.
- Payroll Employee Report: For direct-hire employees.
- Labor Contractor Employee Report: For workers hired through labor contractors.
Both reports must include:
- Pay data: Mean and median hourly pay rate
- Demographic information: Race, ethnicity, and sex
- Workforce Data: Establishment, job category, and pay band
- Total hours worked in 2024
For the 2024 reporting period, a new race/ethnicity category, Middle Eastern or Northern African (MENA), has been added.
How to Submit Pay Data Reports
Employers must submit their reports via the CRD’s Pay Data Reporting Portal. FAQs, updates, and other helpful information are available at: https://calcivilrights.ca.gov/paydatareporting/
Reports may be submitted using one of these three methods:
- Upload an Excel file using CRD’s template
- Upload a CSV file
- Use the portal’s fillable forms
New versions of the pay data reporting Excel templates, CSV examples, user guide, and portal are available on the CRD website.
Penalties for Non-Compliance
Failure to submit the pay data reports may result in CRD seeking a court order and civil penalties of $100 per employee, which increase to $200 per employee for subsequent failures. These penalties are also assessable against a labor contractor who has failed to provide required pay data to a client employer promptly.
Action Steps for Employers
- Review the updated templates and instructions on the CRD portal.
- Collect the required pay and demographic data for your employees and labor contract workers.
- Consult the CRD’s user handbook and FAQs for detailed guidance
- Submit your pay data reports via the CRD portal by May 14th
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