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Friday, November 21, 2025

Changes Are in Store for California Pay Data Reporting, Pay Transparency, and Pay Equity Requirements - Littler Mendelson P.C.

At a Glance

  • New state subcommittee on pay data reporting is charged with reviewing proposed regulations.
  • Senate Bill 464 expands pay data reporting requirements.
  • Senate Bill 642 clarifies and strengthens California’s wage transparency and pay equity laws.

Several legislative and regulatory developments in California are poised to make notable changes to the state’s pay data reporting, pay transparency, and pay equity laws. These measures include a new subcommittee on pay data reporting to review upcoming regulations, a new law to expand pay data reporting obligations, and a new law to clarify terms and enhance pay transparency and pay equity protections.

Subcommittee on Pay Data Reporting

On October 6, 2025, the California Civil Rights Council voted to establish a subcommittee on pay data reporting. This newly formed subcommittee is expected to begin reviewing a nearly finalized package of proposed regulations within the next 30 days.

These regulations are expected to be substantive, not merely procedural, reflecting the employer community’s call for greater clarification on many key unresolved questions regarding California’s pay data reporting requirements. Specifically, the subcommittee will focus on:

  • Defining key terms and concepts within the pay data reporting framework
  • Clarifying what must be reported, not just how to report it
  • Addressing ambiguities that have created challenges for employers

This initiative marks a significant step toward refining the...



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