Update Applicable to:	Due date
All Employers with 100 or More Employees	May 13, 2026

What happened?

The California Civil Rights Department (CRD) released Reporting Year (RY) 2025 pay data reporting materials (including a handbook and frequently asked questions) and published draft filing templates to help employers prepare for the May 13, 2026, deadline.

These materials add new data elements and stress that using the current-year file structure is critical to a successful submission.

Overview

Who is covered: Private employers with 100 or more employees must file if they have at least one employee in California (separate filings apply for payroll employees and for labor contractor workers).

New information requested in Reporting Year 2025

• Exemption status: “Exempt” or “Non-exempt” under California wage orders and/or the federal Fair Labor Standards Act.

• Employment type: full-time, part-time, or intermittent (based on the employer’s standard or alternative workweek schedule).

• Total annual weeks worked: includes weeks with paid time off; reported as a number for each employee group.

File mechanics that changed

• Employee “groups” are now defined by job category, race/ethnicity, sex, pay band, exemption status, and employment type, which increases the number of rows and the detail required.

• Weeks worked must be reported as whole numbers with rounding; the guidance allows employers to choose a reasonable method for partial weeks and recommends consistency and documentation.

• Remote worker reporting is more detailed than in prior years, requiring separate counts tied to remote status and location.

Enforcement and what is next

• Beginning in 2026, Senate Bill 464 requires courts to impose civil penalties when the California Civil Rights Department seeks enforcement for a failure to file a required pay data report.

• Starting in 2027, job categories expand from 10 to 23 using the Standard Occupational Classification framework (replacing the federal job-category approach used previously).

Why this matters

• Increased visibility into classification issues: Reporting exemption status makes potential wage-and-hour misclassification easier for regulators to identify based on data alone.

• More complexity: New grouping fields and whole-number rounding rules can break existing reporting logic and increase the chance of upload errors.

• Higher stakes: Mandatory penalties raise the cost of missing the deadline.

Action Steps for Compliance

• Confirm coverage (including integrated enterprise considerations) and whether you must file one report or two separate reports.

• Update systems now to capture exemption status, employment type, and weeks worked (including paid time off weeks).

• Standardize definitions across locations (especially “intermittent” schedules) and apply them consistently.

• Document the methods used to estimate hours for exempt employees if it is a practice not to track actual hours.

• Coordinate early with labor contractors to obtain weeks and hours worked for workers assigned to you.

• Dry-run the file against the current-year upload rules (dropdown values, whole-number hours, rounding) to catch errors before submission.

Source References

• California Expands Pay Data Reporting Requirements for 2026 (VensureHR)
• CRD – California Pay Data Reporting Resources
• CRD – Handbook Template
• CRD – FAQs for 2025 California Pay Reporting Cycle
• CRD – California Pay Data Reporting Excel Templates

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