- What it is: California's annual employer report on wages broken down by job category, gender, race, and ethnicity , administered by the Civil Rights Department (CRD).
- Who files: Covered private employers with 100 or more payroll employees or private client employers with 100 or more labor contractor employees, with at least one California employee in the relevant group.
- Separate reports: Assess payroll and labor contractor reporting separately. An employer may need both reports.
- Deadline: Reporting Year 2025 reports were due May 13, 2026.
- Penalty risk: A court may impose up to $100 per employee for a first failure and up to $200 per employee for subsequent failures.
California Pay Data Report deadline
The Reporting Year 2025 deadline was May 13, 2026. Use the current CRD reporting page for the applicable reporting cycle. Do not carry an older year's date or enforcement-deferral program into a later year.
Enacted to promote pay equity and combat wage discrimination, California's Pay Data Reporting requirement has its own employer coverage rules. Federal EEO-1 filing status does not determine whether an employer must submit a California pay data report. The data includes pay and workforce information used to analyze potential disparities. This page follows the CRD's Reporting Year 2025 materials, which should not be treated as instructions for a later reporting year.
What Is California Pay Data Reporting?
California's Civil Rights Department (CRD) collects employer pay data each year to identify wage disparities and enforce equal pay laws. The data includes wage information broken down by job category, gender, race, and ethnicity.
Prepare the Right Reporting Year Materials
Use the Reporting Year 2025 templates and matching instructions. The payroll and labor contractor templates are separate files. Confirm the year before transferring data from an older workbook.
Mean & median hourly rates
Under Senate Bill 1162, employers are mandated to compute and report the mean and median hourly rate of their payroll employees and/or labor contractor employees. This must be done for each establishment and broken down by pay band, job category, race/ethnicity, and sex.
Labor Contractor Employee Reports
A private client employer may also owe a separate report for labor contractor employees. The threshold is 100 or more, assessed during the selected snapshot period or on a regular basis during the reporting year, with at least one California labor contractor employee.
Labor contractor penalties
If a contractor does not provide the required information to the employer, the contractor can face penalties for not cooperating.
Who Must File a Pay Data Report?
For California Pay Data Reporting, private employers must file if they meet the following criteria:
- Payroll report: A private employer with 100 or more payroll employees, at least one of whom is a California employee.
- Labor contractor report: A private client employer with 100 or more labor contractor employees, at least one of whom is a California employee.
- Counting: Apply the snapshot-period or regular-basis test, including employees inside and outside California and qualifying employees on leave. Review integrated-enterprise rules for affiliated entities.
These are separate coverage tests. A small California office can be within scope because the threshold considers the broader employee count. See the CRD handbook's Who must file section for definitions and affiliated-employer treatment.
Will California Release Employer Pay Data Information?
Per Government Code section 12999, the Labor Commissioner's Office, CRD, and their staff are forbidden from publicly disclosing individually identifiable information acquired under their authority before initiating an investigation or enforcement action under § 1197.5 of the Labor Code or § 12940 of the Government Code.
Government Code section 12999(h) further deems any individually identifiable information provided to CRD as confidential and not subject to release under the California Public Records Act. The CRD will maintain employer records for no less than ten years.
When Is the Deadline to Submit Pay Data Reports?
Per Government Code section 12999(a), the due date for submitting pay data reports to CRD falls on the second Wednesday of May every year. For Reporting Year 2025, that was May 13, 2026, as confirmed in CRD's 2026 reporting announcement.
Should the CRD not receive the necessary report by the due date, it has the authority to pursue a court order compelling the employer to comply with the pay data reporting regulations. The CRD may recoup costs and the court may levy a civil penalty.
Are Employers Able to Request an Extension?
Do not assume an enforcement deferral announced for an earlier reporting year remains available. Check the current CRD FAQ and reporting page for the relevant cycle, and contact CRD about a filing problem. A request for help is not an approved extension. Keep the required report preparation moving and retain any written agency response with the filing record.
Penalties for Failing to File
With the enactment of Senate Bill 1162, additional penalties apply to employers who neglect to submit required pay data reports. A court may impose civil penalties of up to:
- $100 per employee for failing to file a required report.
- $200 per employee for any subsequent failure.
A court may apportion penalties to a labor contractor that failed to supply required data. CRD may also recover costs associated with an order requiring compliance per Gov. Code § 12999(f).
What Are the Different Types of Pay Data Reports?
Currently there are two different types of California Pay Data Reports:
- Payroll Employee Reports
- Labor Contractor Employee Reports
What Is a Snapshot Period and How Do Employers Pick One?
The "Snapshot Period" refers to a specific pay period falling between October 1 and December 31 of the Reporting Year, as defined in Gov. Code § 12999(b)(4). Employers have flexibility to select any single pay period within this range. The Snapshot Period is used to identify the employees included in the Payroll Employee Report.
Some employers (especially with bi-weekly or monthly payments) wonder how to choose. The key: an employee's inclusion is not determined by whether they were paid during the Snapshot Period, but rather whether they were employed during that time.
Edge Cases & Frequently Asked Questions
Should partial-period employees be included?
Include a California employee who was employed during the selected snapshot period, even if hired or terminated partway through it. Employment during the period matters; an employee on qualifying leave is not automatically excluded merely because no work was performed then.
What about telework from outside California?
Employees who telework from a residence outside California but are assigned to a California establishment may still be classified as California employees and must be included.
What if an employee lives in California but works outside?
Residence alone does not determine inclusion. Report employees assigned to a California establishment or regularly performing job duties in California, including remote work for a non-California establishment. Apply the CRD establishment-assignment rules to the actual snapshot facts.
How do I determine an establishment's "Major Activity"?
Provide a description specific enough to recognize the industry and product or service offered. If an establishment is involved in multiple activities, focus on the activity employing the highest number of workers. Use the North American Industry Classification System (NAICS) for guidance.
Prepare your organization's next filing
Review BoomTax's filing options for your forms, reporting year, and workflow. Keep federal submission, applicable state reporting, and recipient furnishing on your release checklist.
