Labor Contractor Pay Data Handoff Checklist

The CRD Reporting Year 2025 handbook describes a client employer as an employer using workers supplied by labor contractors in its usual course of business. Build an inventory of those suppliers and the workers they supplied, rather than treating every accounts-payable vendor or individual 1099 recipient as a labor contractor employee.

Assess the reporting threshold using the current rules, including nationwide employee counts, the snapshot or regular-basis test and integrated-enterprise considerations. A covered client submits one labor contractor employee report containing the relevant information from its contractors, separately from its payroll employee report. A contractor's own reporting obligation does not replace the client's report.

Use the request worksheet below to specify reporting year, client identity, establishments, proposed snapshot period, source fields, secure delivery route and internal due date. The internal handoff date should leave time for questions and reconciliation. CRD's published deadline for Reporting Year 2025 was May 13, 2026; do not relabel that date for a later year.

The handbook says contractors should provide necessary pay data in a timely manner. Where a contractor uses a subcontractor, the subcontractor is treated as a separate labor contractor for reporting and its data obligation is independent. Ask the primary contact to identify those relationships early so the client does not receive an unexplained combined total at the end.

The client knows its establishment assignments and work performed for its business, while the contractor may hold payroll and demographic source records. Assign field-level ownership and agree how discrepancies will be resolved. Do not assume the party holding a record has already applied CRD's current reporting definition.

In a fictional example, a supplied worker has $60,000 in annual W-2 Box 5 earnings across two clients. Records attribute $40,000 and 1,600 hours to Client A, with $20,000 and 800 hours attributable to Client B. Client A uses its $40,000 portion and 1,600 hours, yielding a $25.00 individual hourly rate for its report.

Using all $60,000 with only Client A's hours would produce $37.50 and overstate that client's measure. The handbook requires allocation based on wages and hours for work performed for the reporting client. Retain the allocation records and reconcile the components to the contractor's source, rather than dividing total annual wages equally across clients without evidence.

Collect the weeks worked for the reporting client as well. Annual earnings determine the relevant pay band under the current instructions; do not use the worker's all-client band automatically when preparing the client's allocated report.

CRD encourages the same or overlapping snapshot periods across contractors, but permits different periods. Record the actual start and end dates for each supplier and confirm the workers employed during that period. Use the California employee and establishment rules, including remote assignments, to identify the detail population.

The verified 2025 labor contractor template has 29 columns, including contractor name, FEIN and snapshot start/end dates. Group using the current establishment and contractor scope plus job category, race/ethnicity, sex, pay band, exemption status and employment type. Calculate employee rates before the group's mean and median, and reconcile annual hours and weeks to the same workers.

Create an exception row for each missing field or unexplained variance, with supplier, affected population, original request date, owner and next deliverable. Preserve follow-up history. A file received is not a complete handoff if it omits subcontractor populations, mixes client allocations or contains obsolete category codes.

CRD requires demographic information collected for pay data reporting to be stored separately from personnel records. Use controlled transfers and keep detailed source access limited to the people performing the reporting work. Give the client's employed certifying official the reviewed output and unresolved issues. The handbook permits another person to electronically file an authorized certification, but the official's review and responsibility remain essential.