The California Civil Rights Department (CRD) has released preliminary versions of updated templates for the 2026 California Pay Data Reports, introducing several new data points that employers will need to collect for the 2025 reporting year. Employers should also be aware of significant structural changes coming in 2027, following the passage of Senate Bill 464 (SB 464).
While the updated templates and FAQs are currently published for planning purposes only and may change before final publication in February 2026, organizations should begin preparing now to maintain pay equity and avoid compliance challenges.
Key Updates for the California 2025 Reporting Year
On November 25, 2025, the CRD published draft templates that introduce new reporting requirements affecting both payroll employee reports and labor contractor reports. Under the updated framework, employers in California will be required to report additional employee classifications, including:
Exempt or non-exempt status;
Employment status, including full-time, part-time, or intermittent (employees who work periodically or do not regularly work full- or part-time hours); and
Total weeks worked during the reporting year, including weeks when the employee was on paid leave such as vacation, holidays, or sick leave.
The CRD has also released updated FAQs alongside the templates. Employers should note that these materials are intended to support early planning and may be revised before official publication.
The pay data reporting portal is expected to open in February 2026, with reports due by May 13, 2026.
Who Is Required to File Pay Data Reports?
California pay data reporting obligations apply to both payroll employees and labor contractor workers, depending on workforce size:
Payroll Employee Report: Private employers with 100 or more employees, including at least one employee in California
Labor Contractor Employee Report: Employers with 100 or more labor contractor workers, including at least one worker in California
A labor contractor is defined as an individual or entity that supplies workers to a client employer to perform labor within the employer's usual course of business.
What Information Must Be Submitted?
For both report types, employers must submit data from one pay period between October 1 and December 31 of the prior year. Workers must be grouped by:
Each group must include:
Employers should also be aware that the Middle Eastern or North African (MENA) race category, introduced last year, remains optional for 2025 reporting.
On the Radar for 2026: New Penalties and Recordkeeping Rules
SB 464, signed into law on October 13, 2025, introduces additional compliance obligations beginning in 2026. These include:
Separate retention of demographic data used for California Pay Data Reports from employees’ other personnel records
Mandatory penalties for non-compliance, which courts are now required to impose
Penalties for failure to submit required records include:
Labor contractors are subject to the same penalties if they fail to provide necessary data to client employers.
Looking Ahead to 2027: Major Structural Changes
The most significant change introduced by SB 464 takes effect in the 2027 filing cycle, when employers will be required to report pay data using 23 job categories that broadly align with Standard Occupational Classification (SOC) groups.
This represents a major departure from the current 10 EEO-1 job categories. Because there is no direct mapping between the existing and new categories, employers should expect a complex transition that may require:
Organizations are strongly encouraged to begin planning well in advance to ensure a smooth transition ahead of the 2027 deadline.
Preparing for Compliance
With expanded data requirements, new penalties, and structural reporting changes on the horizon, California pay data reporting continues to evolve in complexity. Employers should closely monitor CRD updates in early 2026 and assess whether their current systems and processes can support upcoming requirements.
Early preparation will be critical to minimizing compliance risk and avoiding last-minute reporting challenges.
