Employer Alert: 2025 Pay Data Reports are due 5/13/2026!

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It’s that time of year again.  California’s pay data reporting requirement mandates that private employers of 100 or more employees and/or 100 or more workers hired through labor contractors annually report pay, demographic, and other workforce data to the Civil Rights Department (CRD), as required under Government Code section 12999.

Here are some important highlights for the 2025 Reporting Year:

• Deadline: Pay data reports covering the 2025 Reporting Year are due by Wednesday, May 13, 2026. For more information, see FAQ “What is the deadline for submitting a pay data report to CRD?”
• Portal Submission: Covered employers submit their pay data report(s) to CRD through the California Pay Data Reporting Portal (pay data portal) at pdr.calcivilrights.ca.gov. For additional details, see the 2025 California Pay Data Reporting Handbook (handbook) section entitled “How to file”. The Pay Data Reporting Handbook includes a warning that pay data reporting materials from previous years, including pay data reporting templates and user guides, should not be used. Any materials referenced should be for the current reporting year (i.e., Reporting Year 2025).
• Who must file:
• California law requires covered employers to annually report pay, demographic, and other workforce data to CRD. Every private employer with 100 or more payroll employees, at least one of whom is a California employee, is required to file a payroll employee report with CRD annually. In addition, every private client employer with 100 or more labor contractor employees, at least one of whom is a California employee, is required to file a labor contractor employee report with CRD annually. A private employer’s requirement to file a payroll employee report and/or a labor contractor employee report depends on its number of payroll employees and labor contractor employees and, if applicable, the number of payroll employees and labor contractor employees of any affiliated entities in the reporting year.
• An employer has 100 or more payroll employees or 100 or more labor contractor employees if either of the following conditions are met: the employer has 100 or more payroll employees or labor contractor employees during the snapshot period* selected by the employer for the reporting year; or the employer has 100 or more payroll employees or labor contractor employees on a regular basis during the reporting year.
• In the former scenario, every payroll employee or labor contractor employee who is employed during the snapshot period is counted in determining whether an employer has 100 or more employees. In the latter scenario, every employee who is employed on a regular basis during the reporting year, is counted. The count includes employees who work inside and outside of California, as well as employees who are on a paid or unpaid leave of absence from work (but otherwise work for the employer on a regular basis or would be working for the employer during the snapshot period).
• Additionally, a private employer that has fewer than 100 payroll employees and/or less than 100 labor contractor employees is still a covered employer if the employer owns, is owned by, and/or is affiliated with another employer such that the separate entities form an integrated enterprise and the integrated enterprise, collectively, employs 100 or more payroll employees and/or labor contractor employees. The factors to consider in determining whether separate entities form an integrated enterprise include, but are not limited to, the degree of interrelated operations, common management, centralized control of labor relations, and common ownership or financial control over the entities. If an integrated enterprise has 100 or more employees across all affiliated entities, at least one of whom is a California employee, all employers that are a part of the integrated enterprise are covered employers with a reporting obligation, regardless of the number of employees of any particular affiliated entity.

*The “snapshot period” is a single pay period of the employer’s choice between October 1 and December 31 of each reporting year. Employers can get more information on the snapshot period in the handbook section titled “What is the snapshot period?”

• Updated resources: New versions of the pay data reporting Excel templates, CSV examples, user guide, FAQs and portal are available at www.calcivilrights.ca.gov/paydatareporting.
• New data fields for Reporting Year 2025: For Reporting Year 2025, pay data reports should include employees’ exemption status, employment type, and weeks worked during the reporting year.

 

CRD’s support team has provided contact information for employers with additional questions not answered on their website at [email protected]. 

 

As usual, Rosasco Law Group can help you navigate the myriad of employer requirements.  Give us a call for any of your reporting or compliance needs.