The California pay data reporting portal opened on February 2, 2026, giving covered employers an early opportunity to begin preparing their annual submissions. While reports are not due until May 13, 2026, experienced California employers know that this is not a process best left to the final weeks.
The California Civil Rights Department (CRD) continues to refine its pay data reporting requirements, resources, and templates each year. For employers with California employees, early preparation allows time to review updated guidance, confirm data accuracy, and address questions before the deadline.
California law requires private employers with 100 or more payroll employees, and private client employers with 100 or more labor contractor employees to annually submit pay, demographic, and workforce data to the CRD under California Government Code section 12999.
The state collects this data to encourage employer self-assessments of pay disparities, promote voluntary compliance with equal pay and anti-discrimination laws, and support enforcement of California’s civil rights protections.
For Reporting Year 2025, employers must report:
-
The number of employees by race, ethnicity, and sex across 10 job categories
(The expansion to 23 job categories will not take effect until 2027.)
-
The number of employees by race, ethnicity, and sex whose annual earnings fall within each pay band used by the U.S. Bureau of Labor Statistics’ Occupational Employment and Wage Statistics survey
-
Median and mean hourly rates within each job category for each combination of race, ethnicity, and sex
This data often requires coordination between HR, payroll, and third-party vendors, making early review especially valuable. As expected, the CRD has updated its reporting templates and guidance for RY 2025. Employers must now also report:
-
Exemption status
-
Employment type (full-time, part-time, or intermittent)
-
Weeks worked during the reporting year
Even employers with established reporting processes should take time to review the updated CRD resources to ensure their systems accurately capture this information. Pay data reporting is not just about meeting a statutory requirement; it is also a valuable checkpoint for evaluating compensation practices. Approaching pay data reporting as part of a broader pay equity and compliance strategy can help reduce risk and support more defensible compensation practices over time.
Members with California employees are encouraged to reach out to the Employers Council California Legal Services team with questions about pay data reporting requirements, challenges in preparing for them, or strategic considerations.
If you would like assistance as you begin preparing your RY 2025 report, contact us at CAinfo@employerscouncil.org
Brittanie Young, SHRM-SCP, is an HR Consultant with Employers Council's California Legal Services