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). This reporting is required under Government Code section 12999, as amended by Senate Bill 1162. California’s pay data reporting deadline for Reporting Year 2025 is May 13, 2026, and employers do not have to wait until the portal opens to see this year’s reporting requirements. The California CRD has already posted preliminary pay data templates and a preliminary FAQ, giving employers an early look at data the CRD expects to collect this year.

What is changing this year

The big update is that the CRD is building three new required fields into both the Payroll Employee Report and the Labor Contractor Employee Report, which are:

1. Exemption Status: Employers will need to identify whether each California employee is exempt from minimum wage and overtime requirements under California wage orders and/or the Fair Labor Standards Act: pay data reporting is now pulling exemption status directly into the submission itself.
2. Employment Type: Instead of only the usual full time and part time split, the CRD adds a third bucket: intermittent (intended for periodic or irregular schedules). This is a notable shift from the usual full time or part time framework, and it suggests the CRD is aiming for more precise comparisons across employees with similar schedules.
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