California employers must begin preparing now to meet the May 14, 2025 deadline for the state’s pay data reporting obligations. As mandated by California law, private employers with 100 or more employees and/or 100 or more workers hired through labor contractors in the prior calendar year must submit detailed pay data reports to the California Civil Rights Department (CRD). This requirement applies even to employers based outside of California if they have at least one employee working in or assigned to a California establishment.

By requiring annual submission of pay data, California aims to promote transparency and voluntary compliance with equal pay and anti-discrimination laws by identifying wage patterns along gender, racial, and ethnic lines.

1. Deadline to File is Wednesday, May 14, 2025

The CRD Pay Data Reporting Portal opened on February 3, 2025. All reports must be submitted and certified through this portal no later than May 14, 2025. Submissions outside the portal or in non-digital formats will not be accepted and will be deemed non-compliant​.

2. Who Must File

Private employers must file if they meet either of the following thresholds in the 2024 calendar year:

  • Employed 100 or more payroll employees (part-time and full-time), with at least one working in or assigned to California.
  • Had 100 or more labor contractor employees (i.e., workers provided by a staffing agency), with at least one working in or assigned to California.

An employer is also required to report if they are part of an integrated enterprise that collectively employs 100 or more workers across affiliated entities​.

3. What to Include in the Report

The required reports must include:

  • Median and mean hourly pay rate by establishment, job category, pay band, sex, race, and ethnicity.
  • Total hours worked in the 2024 reporting year.
  • Classification of remote workers, including:
    • Remote workers located in California.
    • Remote workers outside of California assigned to a California establishment​.

The Snapshot Period for determining which employees to include in the report is any single pay period between October 1 and December 31, 2024.

4. Remote Worker Reporting Requirements

Employers must distinguish between fully remote employees and hybrid workers. Remote workers are defined as those with no expectation to regularly report in person to a physical worksite. If an employee reports to a physical establishment—even occasionally—during the Snapshot Period, they are not classified as a remote worker​

All employees working remotely in California, or working outside California but assigned to a California establishment, must be included in the report.

5. Labor Contractor Employee Reports

If a business used 100 or more labor contractor workers in 2024, it must file a separate Labor Contractor Employee Report. This applies even if these workers were not on the business’s payroll.

Employers must:

  • Identify labor contractors used.
  • Report data for workers assigned to California establishments or working within California.
  • Provide each labor contractor’s name, FEIN, and Snapshot Period dates​

This reporting obligation does not apply to 1099 independent contractors.

Noncompliance may result in CRD seeking a court order and civil penalties of up to $100 per employee, and $200 per employee for subsequent failures. If a labor contractor fails to provide necessary data to a client employer, it may also be held liable​

All reports must be submitted via the CRD’s Pay Data Reporting Portal: https://pdr.calcivilrights.ca.gov
FAQs and updates are available at: https://calcivilrights.ca.gov/paydatareporting

Reports may be submitted using:

  • CRD’s Excel template,
  • CSV file upload, or
  • Online fillable forms.

For 2025, the CRD has placed a strong emphasis on certification, and certifying official of the employer—not a third-party HR provider—must review and certify the report before submission.