The California Civil Rights Department (CRD) has issued preliminary guidance, updated FAQs, and draft reporting templates for the 2025 Pay Data Reporting cycle, with reports currently due May 13, 2026. While these materials are labeled preliminary and may be refined before final release, they signal meaningful reporting changes that covered employers should address now not at the last minute. If you have 100 or more employees you must submit data to the CRD.
At JorgensenHR, we recommend early planning and system readiness to reduce risk, avoid reporting errors, and streamline your compliance process. Below is a practical summary of what’s changing and what employers should be doing today.
WHAT’S NEW IN THE UPCOMING REPORTING CYCLE
In addition to the traditionally required data elements race/ethnicity, sex, job category, and pay band CRD’s preliminary materials introduce several new data fields that expand reporting detail and complexity:
- Exemption Status — Whether the employee is classified as exempt or non-exempt for minimum wage and overtime purposes
- Employment Type — Full-time, part-time, or intermittent classification
- Weeks Worked — Total weeks worked during the reporting year, including paid leave such as vacation and sick time
CRD has indicated these new data points will be optional for this reporting cycle, but they are widely expected to become mandatory in future years. Employers that are not currently tracking this information should begin updating their HRIS and payroll processes now.
PRELIMINARY TEMPLATES AND FAQS RELEASED
CRD has also published draft Excel templates and FAQs covering both:
- Payroll Employee Reports
- Labor Contractor Employee Reports
These templates are provided strictly for advance planning purposes and should not be used for submission. Official templates and final instructions are expected when the CRD reporting portal reopens in February 2026.
Early review of these drafts can help employers identify data gaps and avoid last-minute reporting challenges.
MANDATORY PENALTIES NOW IN EFFECT
A critical enforcement change is also on the horizon. Under SB 464, signed into law in October, civil penalties for noncompliance with California pay data reporting requirements will become mandatory starting in 2026. Previously, courts had discretion in assessing penalties. Going forward, penalties must be imposed upon CRD request significantly increasing employer exposure for missed or inaccurate filings.
5-STEP EMPLOYER ACTION PLAN
To stay ahead of these changes, JorgensenHR recommends that covered employers take the following steps now:
- Update HR and payroll systems to capture exemption status, employment type, and weeks worked
- Engage labor contractors early to confirm their ability to produce expanded reporting data
- Audit your data pipelines to ensure accurate grouping and aggregation across new categories
- Monitor CRD updates and be prepared to adjust once final templates are released in February 2026
- Consult with experienced HR and legal advisors to validate your reporting strategy and submission accuracy
LOOKING AHEAD: EXPANDED JOB CATEGORIES IN 2027
Beginning with the following reporting cycle, required job categories will expand from 10 to 23 classifications under SB 464 — further increasing reporting detail and employer obligations.
HOW JORGENSENHR HELPS
JorgensenHR works with employers to align HR, payroll, and compliance systems so reporting obligations are met accurately and efficiently. From data readiness reviews to full compliance support, our team helps minimize risk and maximize compliance.
If you would like help preparing for California pay data reporting requirements, we’re here to support you.
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