New Requirements for California Pay Data Reporting

By Emily Kimble

Blog Overview: The California Civil Rights Department (CRD) has published updated templates for the 2026 California Pay Data Reports. These templates include multiple new requirements for the 2025 reporting year. Employers should also be prepared for major changes to reporting in 2027.

On November 25, 2025, the California Civil Rights Department (CRD) published preliminary versions of updated pay data reporting templates for the 2025 Reporting Year that will impact reporting requirements. These new requirements, which affects both payroll and labor contractor reports, include:

• Whether an employee is exempt or non-exempt.
• Full-time, part-time, or intermittent status (i.e., an employee who works periodically or does not regularly work full- or part-time hours).
• Weeks worked during the reporting year, including weeks during which the employee was on paid leave (e.g., vacation or holidays, as well as sick leave).

CA CRD’s Frequently Asked Questions document and updated templates can be found here. Note that these resources are for planning purposes and may change before official publication in February 2026.

The portal is expected to open in February. Reports will be due by May 13, 2026.

Who Must File?

• Payroll Employee Report: Private employers with 100 or more employees, including at least one in California.
• Labor Contractor Report: Employers with 100 or more labor contract workers, including at least one in California. A labor contractor is defined as “an individual or entity that supplies a client employer with workers to perform labor within the client employer’s usual course of business.”

What Must be Submitted?

For both reports, employers must submit data for a single pay period from between October 1 and December 31 of the prior year, with workers grouped by establishment, pay band (based on W-2 Box 5 earnings), EEO-1 job category, and race/ethnicity, and sex. Each group will list the employee count, mean and median hourly rates, total hours worked, and total weeks worked which, as noted previously, is a new requirement.

As a reminder, the Middle Eastern or North African (MENA) race category added last year remains optional for 2025 reporting. Reference DCI’s blog for an overview of other changes over the years and frequently asked questions.

On the Radar for 2026

Employers should note Senate Bill 464 (SB 464), signed into law on October 13, 2025,  by CA Governor Gavin Newsom. The bill includes important new requirements for employers in 2026, including:

• Separate retention of demographic data used for CA Pay Data Reports from employees’ other personnel records.
• Mandatory penalties for failure to submit records to the CRD. Courts are now required to impose these penalties. Labor contractors face the same penalties for failing to provide data to filing employers. These penalties include:
  • $100 per employee (first violation)
  • $200 per employee (subsequent violations)

Looking Ahead to 2027

However, the most significant update stemming from SB 464 is that employers will be required to use 23 job categories that generally align with Standard Occupation Classification (SOC) groups starting with the 2027 Filing Cycle. Currently, the California Pay Data Report aligns with the 10 EEO-1 categories. See our previous blog for the new list of categories required by SB 464.

Because there is no direct mapping to the new job categories, this transition will likely require substantial effort. Organizations should start planning before 2027 to allow ample time for validation and system updates.

DCI is ready to partner with clients to help streamline this process and provide expert support. In the meantime, we will continue to monitor the updates on this year’s Pay Data Reporting requirements.