California Pay Data Reporting: Repeat Penalties Rise to $1,000

BLOG OVERVIEW: California SB 1237, signed September 30, 2026, raises the maximum penalty for repeat failures to file the annual California Pay Data Report from $200 to $1,000 per employee, effective January 1, 2027. First-time failures remain capped at $100 per employee, and SB 464 already makes these penalties mandatory when the Civil Rights Department seeks enforcement. CRD’s September 2026 petition against Coast 2 Coast Coaching shows the risk: an employer with 2,100 employees could face $2.1 million for a single missed year. Employers should also prepare to report by 23 SOC-aligned job categories ahead of the May 12, 2027, deadline.

On September 30, 2026, California Governor Gavin Newsom signed SB 1237, substantially increasing the maximum penalties for employers that repeatedly fail to file the annual California Pay Data Report. First-time violations still carry a maximum penalty of $100 per employee, but starting January 1, 2027, subsequent failures to file will jump from $200 to $1,000 per employee.

This is the second change in as many years to California’s pay data reporting penalties. Senate Bill 464 (SB 464), signed October 13, 2025, made the penalties mandatory for the courts rather than discretionary.

As a reminder, private employers with 100 or more payroll employees, or 100 or more workers hired through labor contractors, must file annually if at least one of those workers is in California. The 100-worker count includes employees outside the state.

Recent Action Taken Against Non-Compliant Employer Shows Potential Impact of Penalties

The California Civil Rights Department (CRD) recently filed a petition against Coast 2 Coast Coaching, Inc. According to the filing, the employer is alleged to have failed to file 2024 and 2025 pay data reports for its more than 2,100 employees throughout California. If the previous maximum penalties are imposed ($100 per employee for 2024 and $200 per employee for 2025), an employer of this size could be penalized up to $630,000 ($210,000 for 2024 and $420,000 for 2025), plus any associated court costs and attorneys' fees. With the newly increased penalty amounts, an employer of this size that fails to file its 2026 report could be penalized up to $2,100,000 for that year alone.

Enforcement against non-compliant employers is not isolated. CRD’s most recent press release on employers failing to file makes it clear that, though the federal government has taken steps to end national workforce data collection, California has no intention of doing the same. With SB 1237, it will have significantly more leverage over employers that do not comply.

Other Changes in California Pay Data Reporting for 2027

SB 464 also requires employers to begin reporting their data by 23 SOC-aligned categories in place of EEO-1 categories starting in 2027 (with 2026 data). With employers facing much larger penalties for failures to file, it is important for employers to begin assigning the new SOC categories to employees included in the reporting, well before 2027 reports are due on May 12, 2027.

DCI will continue to monitor legislative changes in the state of California and is available to help employers navigate mapping to the new reporting categories.