California 2024 Pay Data Reporting

Deadline is May 14, 2025

Employers operating in California should be aware of the 2024 Pay Data Report deadline of May 14, 2025.

By May 14, 2025, employers with 100 or more employees or 100 or more workers hired through labor contractors (where at least one of these workers is in California) must submit workforce pay data reports to California’s Civil Rights Department (CRD). This legal requirement aims to ensure compliance with equal pay laws and anti-discrimination standards. The CRD opened its 2024 pay data reporting portal on February 3, 2025.

What Are the Reporting Requirements?

Under California law, large employers must submit detailed pay data reports yearly to the CRD. These reports capture information regarding employee demographics, pay bands, hours worked, and additional workforce metrics. The primary goal of this regulatory measure is to address wage disparities and enforce California’s equal pay and anti-discrimination laws.

For 2024, qualifying employers must submit two specific types of reports:

• Payroll Employee Reports: Covering all employees on the company’s payroll during the reporting year.
• Labor Contractor Employee Reports: Focusing on workers hired through labor contractors during the previous calendar year.

Key Changes for 2024 Reporting

While the reporting requirements for 2024 are essentially unchanged from the 2023 program, there is one noteworthy update. The CRD has introduced a new race and ethnicity category for reporting purposes: “Middle Eastern or North African (MENA).” Employers will need to factor in this expanded demographic category to comply with the revised reporting format accurately.

To help employers prepare, the CRD has published updated documentation, including templates, handbooks, and user guides, which reflect this new reporting element.

What Are the Penalties for Noncompliance?

California takes pay data reporting requirements seriously, and employers that fail to comply could face significant penalties:

• Civil Penalties: Employers may be fined $100 per employee for the first instance of noncompliance. The penalty increases to $200 per employee for repeated failure to file.

• Enforcement Actions: The CRD and state courts can compel noncompliant employers to file their reports and cover all associated enforcement costs.

Next Steps for Employers

To ensure full compliance and avoid financial penalties, employers should take the following actions:

• Review Reporting Criteria – Verify whether your business meets the reporting threshold of 100 or more employees or labor contractor workers. If your business qualifies, familiarize yourself with the data points and categories required for Payroll Employee Reports and Labor Contractor Employee Reports.
• Prepare Data Early – Begin collecting and organizing pay data, hours worked, and demographic information. Make sure the data is accurate, particularly with the inclusion of the new MENA category.
• Coordinate With Labor Contractors – Employers relying on labor contractors should work closely with these entities to ensure that all necessary worker information is available in time for submission.
• Use Resources Provided by CRD—To understand the specifics of preparing and submitting your pay data reports, Refer to the CRD’s comprehensive frequently asked questions, handbook, and user guide.
• Submit Via the CRD Online Portal—Employers can begin submitting their 2024 reports through the CRD’s portal, which opened on February 3, 2025. To avoid penalties, ensure the reports are filed on or before May 14, 2025.
• Consult Experts as Needed – Navigating pay data reporting requirements can be complex. Employers may benefit from consulting HR professionals or legal advisors to ensure their compliance process is thorough and effective.

Employers subject to California’s pay data reporting requirements should act promptly to collect and prepare the necessary information for submission through the CRD’s portal. The reporting process serves as a compliance measure and an opportunity to assess your organization’s pay practices and ensure alignment with California’s standards on workplace equity.

If you have questions or need further guidance, refer to the CRD’s published resources or consult a qualified expert to facilitate a smooth reporting process.