By Emily Kimble and Victoria Ungvary
BLOG OVERVIEW: California’s SB 464, signed in October 2025, overhauls the state’s pay data reporting requirements and most notably replaces the 10 EEO-1 job categories with 23 SOC-based categories beginning with the 2027 filing cycle (covering 2026 reporting-year data). Because the new categories often span multiple EEO-1 classifications, there is no clean one-to-one crosswalk, so employers should begin mapping job titles now to ensure data accuracy ahead of the anticipated May 12, 2027, deadline. SB 464 also makes penalties for failure to file mandatory rather than discretionary—$100 per employee for a first violation and $200 for subsequent violations—creating significant exposure even for mid-size employers.
With the 2026 California Pay Data Reporting cycle complete, employers should now turn their attention to a significant change taking effect in 2027 for 2026 reports. In October of 2025, California Governor Gavin Newsom signed Senate Bill 464 (SB 464) into law, introducing several changes to California’s state pay data requirements. Among these changes is a new job classification framework that will take effect beginning with the 2027 filing cycle.
Beginning with the 2027 filing cycle, employers must submit pay data using 23 job categories aligned to the Standard Occupational Classification (SOC) system—a significant shift from the 10 EEO-1 categories that have been required over the past five years.
SB 464 requires reporting across the following 23 job categories:
The above job categories mirror the SOC Major Groups, with one notable exception. Whereas the SOC system has a single Management Occupations major group, California will have two management categories: (A) Chief Executives and (B) Management occupations, except chief executives.
What Does this Mean for Employers?
Employers should begin preparations to map their job titles to the new California job categories now. Because California's new job categories often span multiple EEO-1 classifications, there is no straightforward one-to-one crosswalk between the two. While some categories can be mapped directly, most jobs will require detailed review and reclassification. Starting this process well ahead of 2027 will allow adequate time for data accuracy and validation.
Organizations that have maintained Census Occupation Codes or SOC codes for their positions can utilize the EEO 2014-2018 Occupation Crosswalk released by the Census Bureau to assist with the reclassification.
It is worth noting that California appears to have moved away from references to federal EEO-1 alignment in its frequently asked questions and handbook guidance, a trend that continued through the 2026 filing cycle. With ongoing uncertainty around EEO-1 reporting at the federal level, this shift may reflect California’s intent to establish a more granular, independent reporting framework. The broader EEO-1 categories have long been criticized for grouping employees with substantially different pay bands and job duties, and the new SOC-based categories could help to address that limitation.
Upcoming 2027 Filing Cycle
The 2027 filing cycle is anticipated to open in early February based on prior years, with pay data reports due May 12, 2027. The 2026 reports are expected to include the same fields as the 2025 reports, with the inclusion of the new job categories. Employers must submit data for the selected pay period with employees grouped by establishment, pay band, job category, race/ethnicity and sex, exempt status, and employment type (full-time, part-time, or intermittent). Each aggregated group must also include mean and median hourly rates, hours worked, and weeks worked, along with employee counts by remote status for workers located within and outside California.
If the 2027 requirements mirror 2026, exempt status, employment type, and weeks worked will remain optional fields. The California Civil Rights Department (CRD) declined to confirm whether these fields would remain optional, so employers should assess what data is currently readily accessible in their systems ahead of the filing period.
Penalties for Non-Compliance
SB 464, which took effect in 2026, also made changes to penalties for failure to file. Previously penalties were discretionary; now the courts are required to impose penalties of:
Given the penalties are assessed per employee, even mid-size employers can face significant financial exposure for non-compliance. These penalties can also be apportioned to labor contractor employers that fail to provide the requested data to another employer.
DCI will continue to monitor the California Civil Rights Division website for additional guidance and resources as they become available. In the meantime, DCI is available to help clients navigate this mapping process.