## Who Must File
Every private employer with 100 or more employees — including those hired through labor contractors — must submit an annual pay data report to the California Civil Rights Department (CRD). This applies regardless of where your company is headquartered, as long as you have 100+ employees with at least one in California.
What Data Is Required
The report breaks down employee compensation by job category, race/ethnicity, and gender. Specifically, you must report W-2 earnings and hours worked for each employee, categorized into the 10 EEO-1 job categories. For labor contractor employees, a separate report is required.
The May 13, 2026 Deadline
The filing window for the 2025 reporting year closes on May 13, 2026. This is for pay data from the prior calendar year (2025). The CRD's online portal is the only accepted submission method.
Penalties for Non-Compliance
First violation: $100 per employee. Subsequent violations: $200 per employee. For a company with 500 employees, a first-time miss costs $50,000. There is no grace period — the penalty applies automatically if you fail to file by the deadline.
What Changed in 2026
California amended its pay transparency law (SB 642, effective January 1, 2026) to redefine "pay scale" as a "good faith salary estimate." This narrows the definition and creates new interpretation requirements that employers must incorporate into their reporting.
How to Prepare
- Audit your employee data now — ensure race/ethnicity and gender data is complete for all employees
- Verify your EEO-1 job category mappings are current
- Calculate W-2 earnings and hours worked for each employee by category
- Test the CRD portal access before the deadline rush in early May
- Document your methodology in case of a CRD inquiry
The Multi-State Complication
If you also have employees in New York, Colorado, Illinois, or any of the other 17+ states with pay transparency laws, your California filing is just one piece of a larger compliance picture. Each state has different requirements, thresholds, and deadlines that must be tracked simultaneously.