Employment Law Alert: California’s 2024 Pay Data Reporting Deadline is May 14, by Kartikey Pradhan, 5-7-2025

Private employers in California with 100 or more employees or 100 or more workers hired through labor contractors must submit their 2024 pay data reports to the California Civil Rights Department (CRD) by Wednesday, May 14, 2025.

This requirement, under Government Code section 12999 as amended by Senate Bill 1162, aims to promote equal pay and anti-discrimination efforts across the state.

Key Reporting Requirements (as per the California Pay Data Reporting Handbook):

• Two Report Types: There are two separate California pay data reports: the Payroll Employee Report and a Labor Contractor Employee Report. Employers may be required to file one or both types of reports. California law requires private employers with 100 or more payroll employees inside or outside of California (and at least one California employee) in the prior calendar year to file a Payroll Employee Report. A private employer that is a client employer with 100 or more labor contractor employees (i.e., workers hired through labor contractors) inside or outside of California (and at least one California labor contractor employee) in the prior calendar year must file a separate Labor Contractor Employee Report. A private employer’s requirement to file a Payroll Employee Report and/or a Labor Contractor Employee Report depends on its staffing levels and, if applicable, the staffing levels of any affiliated business entities in the reporting year.

• Demographic and Pay Data: Reports must include the number of employees by race, ethnicity, and sex in various job categories, as well as the number of employees by race, ethnicity, and sex whose annual earnings fall within each of the pay bands used by the U.S. Bureau of Labor Statistics in the Occupational Employment and Wage Statistics Survey.

• Median and Mean Hourly Rates: Senate Bill 1162 requires employers to calculate and report the mean and median hourly rate of its payroll employees and/or labor contractor employees, by establishment, job category, pay band, race/ethnicity, and sex.

New for 2024:

• Additional Race/Ethnicity Category: “Middle Eastern or North African (MENA)” has been added as a new race/ethnicity category.
• Updated Templates: Employers must use the new Excel templates and CSV examples provided by the CRD.

Penalties for Non-Compliance:

Failure to submit the required reports can result in civil penalties of up to $100 per employee for failing to file the required report/reports and up to $200 per employee for subsequent violations.

Next Steps:

• Access the Reporting Portal: Employers can submit their reports through the CRD’s online portal.
• Review the Handbook and User Guide: The CRD has provided a handbook and user guide to assist employers in completing their reports accurately.
• Consult the FAQs: The CRD’s FAQ addresses common questions and provides clarification on reporting requirements.

Employers are encouraged to begin preparing their reports promptly to ensure compliance with the May 14 deadline. For more information, visit the CRD’s Pay Data Reporting page.

Author: Kartikey Pradhan is a Partner in KD’s San Francisco office