California Pay Data Reporting Requirements: CRD Updates Employers Need to Know for 2026
California employers subject to the state’s pay data reporting law should take note of newly updated guidance issued by the California Civil Rights Department (CRD). In February 2026, the CRD released updated resources, templates, and instructions for employers preparing their California pay data report for the 2025 reporting year, which is due May 13, 2026.
These updates affect how covered employers collect, classify, and submit workforce compensation and demographic information and signal continued expansion of California’s pay equity enforcement framework.
Overview of California Pay Data Reporting Law
California pay data reporting requirements are codified in Government Code section 12999. The law applies to private employers with 100 or more employees and to employers with 100 or more workers hired through labor contractors. Covered employers must annually submit pay and demographic data to the CRD through its online reporting portal.
The stated purpose of California’s pay data reporting law is to assist the state in identifying potential pay disparities and enforcing equal pay and civil rights protections. According to the CRD, the collected data helps evaluate wage patterns across gender, race, and ethnicity within California’s workforce.
California Pay Data Report Deadline for 2026
For the 2025 reporting year, California employers must submit their pay data reports to the CRD no later than May 13, 2026. Reports are submitted electronically using the CRD’s standardized templates and reporting portal.
Employers that fail to submit a required report risk enforcement action by the CRD, including potential civil penalties under recently amended law.
What the CRD Updated for Pay Data Reporting in 2026
The CRD’s February 2026 update includes revised employer resources designed to assist with compliance. These updates include new versions of the official Excel and CSV submission templates, revisions to the Pay Data Reporting Handbook, and expanded Frequently Asked Questions addressing common reporting issues.
The updated templates reflect changes to the data fields employers must now report and are intended to standardize submissions across industries.
New Data Fields in California Pay Data Reports
Although California pay data reporting continues to rely on established job categories, the 2025 reporting year introduces additional mandatory data elements. Employers are now required to report, for each employee included in the report:
- Exemption status (exempt or non-exempt)
- Employment type (full-time, part-time, or intermittent)
- Total weeks worked during the reporting year
These expanded data fields require employers to coordinate closely with payroll systems and human resources records to ensure accurate classification and reporting.
Labor Contractor Pay Data Reporting Obligations
California employers that rely on labor contractors must also account for labor contractor pay data reporting obligations. When coverage thresholds are met, employers must submit a separate labor contractor employee report containing pay and demographic data for workers supplied by labor contractors.
This requirement often necessitates early communication and data-sharing agreements between employers and labor contractors to avoid incomplete or inaccurate submissions.
SB 464 and Increased Enforcement Risk
Recent legislative changes have increased the stakes for non-compliance. Senate Bill 464, signed by Governor Gavin Newsom in October 2025, strengthened the CRD’s enforcement authority related to pay data reporting. Under SB 464, courts must impose civil penalties when the CRD seeks enforcement for a failure to file a required pay data report.
SB 464 also requires employers to maintain demographic data used for pay data reporting separately from regular personnel files, adding new recordkeeping considerations for California employers.
Preparing for Future California Pay Data Reporting Changes
The CRD has also signaled that future reporting years will involve even more detailed requirements, including expanded occupational classifications beginning with reports due in 2027. Employers should view the 2026 reporting cycle as an opportunity to audit internal data systems and prepare for increased complexity in future submissions.
Practical Compliance Considerations for California Employers
California employers subject to pay data reporting requirements should consider reviewing the CRD’s updated guidance as early as possible, confirming that payroll and HR systems capture the newly required data fields, and coordinating with labor contractors well in advance of the reporting deadline. Employers may also wish to evaluate internal pay equity practices to identify and address potential disparities before submitting required reports.
Conclusion
California pay data reporting obligations continue to expand, and the CRD’s 2026 updates reinforce the state’s commitment to pay equity enforcement. Employers covered by Government Code section 12999 should take proactive steps to understand updated reporting requirements, meet filing deadlines, and reduce compliance risk in an increasingly regulated environment.