California law requires private employers with 100 or more employees and/or 100 or more workers hired through labor contractors to annually report pay, demographic, and other workforce data to the Civil Rights Department (CRD). The CRD has now released preliminary templates, updated FAQs, and opened the pay data portal for Reporting Year 2025. The deadline to file is May 13, 2026.

This year’s reporting cycle introduces three new mandatory data fields, expands how employee groups are defined, and increases the overall complexity of submissions for both payroll employee reports and labor contractor employee reports.

Who Must File

Two categories of employers are subject to California’s pay data reporting requirements:

• Payroll Employee Report: Private employers with 100 or more payroll employees, including at least one employee in California.
• Labor Contractor Employee Report: Private employers with 100 or more workers hired through labor contractors, including at least one such worker in California. A labor contractor is defined as an individual or entity that supplies a client employer with workers to perform labor within the client employer’s usual course of business.

What Must Be Submitted

For both report types, employers must submit data for a single “snap-shot” pay period from between October 1 and December 31 of the reporting year. Workers are grouped by establishment, pay band (based on W-2 Box 5 earnings), EEO-1 job category, race/ethnicity, and sex. Each group...

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