After more than twenty years defending California employers, I have seen a consistent pattern: even companies with sophisticated systems struggle with one of the most fundamental compliance obligations in California employment law—maintaining, accessing, and analyzing employee time records. These challenges are not merely operational inconveniences. They routinely lead to unnecessary legal exposure, inflated PAGA penalties

SB 973, a new California law passed in September 2020, created a new obligation for California employers to annually submit pay data report to the Department of Fair Employment and Housing (DFEH).  The DFEH has recently published a frequently asked questions page clarifying some questions about SB 973.  Here are five issues California employers