California Annual Pay Data Reporting Opens

Pay Data

The California Civil Rights Department (CRD) updated its pay data reporting resources for 2024. Employers should start thinking about their annual pay data reports — due this year on May 8 — as they can start submitting them today!

Since 2020, California has required employers with at least 100 employees to submit pay data reports to the CRD, with some major changes to the law taking effect just last year. Employers must report detailed information covering a snapshot period of the previous year, including:

  • The number of employees by race, ethnicity and sex in 10 different job title categories;
  • 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 Statistics survey; and
  • The median and mean hourly rate within each job category, for each combination of race, ethnicity and sex.

In addition to reports covering payroll employees, last year’s revisions to the law expanded the reporting requirements to cover “labor contractor employees” — i.e., workers who are performing labor for the client employer but are on the labor contractor’s payroll. As of last year, employers that have 100 or more workers hired through labor contractors are required to submit a labor contractor employee report, which is a separate report than is required for traditional payroll employees.

The CRD has released updated Microsoft Excel and CSV templates for this year’s report on its pay data reporting website, as well as an updated User Guide and FAQs. Some notable announcements for this year include:

  • New for this year: Employers must report whether employees worked remotely during the snapshot period.
  • For labor contractor employee reports, reporting “unknown” race/ethnicity or sex of a labor contractor employee is no longer permitted.
  • Employers can’t use Excel templates or .CSV examples from prior years; the portal will reject submissions based on outdated versions of the templates.

Employers should begin reviewing the resources and templates and preparing their reports. Employers that are required to submit labor contractor employee reports should start soon since they will have to work with their labor contractors to obtain the required information.

The pay data reporting portal opened on February 1, 2024, so employers can file their reports until May 8, 2024 — which is the latest they can be filed.

James W. Ward, Employment Law Subject Matter Expert/Legal Writer and Editor

CalChamber members can read more about “Pay Data Reporting in California” in EEO Reporting Requirements in the HR Library. Not a member? Learn about the benefits of membership.

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