California employers must begin preparing now to meet the May 14, 2025 deadline for the state’s pay data reporting obligations. As mandated by California law, private employers with 100 or more employees and/or 100 or more workers hired through labor contractors in the prior calendar year must submit detailed pay data reports to the California Civil Rights Department (CRD). This requirement applies even to employers based outside of California if they have at least one employee working in or assigned to a California establishment.

By requiring annual submission of pay data, California aims to promote transparency and voluntary compliance with equal pay and anti-discrimination laws by identifying wage patterns along gender, racial, and ethnic lines.

1. Deadline to File is Wednesday, May 14, 2025

The CRD Pay Data Reporting Portal opened on February 3, 2025. All reports must be submitted and certified through this portal no later than May 14, 2025. Submissions outside the portal or in non-digital formats will not be accepted and will be deemed non-compliant.

2. Who Must File

Private employers must file if they meet either of the following thresholds in the 2024 calendar year:

• Employed 100 or more payroll employees (part-time and full-time), with at least one working in or assigned to California.
• Had 100 or more labor contractor employees (i.e., workers provided by a staffing agency), with at least one working in or assigned to California.

An employer is also required to...

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