California Employers: Your Pay Data Reporting Deadline Is Approaching

Earlier this year, we published an overview of California’s 2024 pay data reporting requirements. With the May 14, 2025 submission deadline now fast approaching, it is essential for covered employers to refocus their attention on compliance.

This follow-up is intended to reaffirm core reporting requirements, highlight notable updates for the 2024 cycle, and outline practical steps employers should be taking now. While many of the rules remain unchanged from prior years, several important developments, as well as the risk of substantial penalties for noncompliance make timely and accurate reporting a priority.

If your organization has questions about the reporting process or would like assistance reviewing your filings, please contact our Managing Partner, Richard Liu, at contact@consultils.com for tailored guidance and support.

Who Is Required to File?

The California Civil Rights Department (CRD) requires private employers to submit pay data reports if, during the 2024 calendar year, they:

• Employed 100 or more individuals, with at least one employee located in California; or

• Retained 100 or more labor contractor workers, with at least one assigned to a California worksite.

  
  

Depending on workforce composition, employers must file a Payroll Employee Report, a Labor Contractor Employee Report, or both.

Key Changes for 2024

Introduction of a New Race/Ethnicity Category

The CRD has added a new race/ethnicity classification: Middle Eastern or North African (MENA). Employers may report employees under this category if the information is available. If not, they should continue following prior guidance, which grouped MENA individuals under the "White" category. As with other demographic data, self-identification remains the preferred method of collection.

Updated Reporting Resources

To support compliance efforts, the CRD has issued revised guidance for the 2024 reporting cycle. The updated Pay Data Reporting Handbook provides comprehensive instructions on reporting requirements, definitions, and the certification process. The accompanying Portal User Guide offers step-by-step directions for completing and submitting both the Payroll Employee Report and the Labor Contractor Employee Report.

The CRD has also enhanced the reporting portal and Excel templates to improve clarity and ease of use. Employers must ensure they are using the most current versions, as outdated templates will not be accepted.

Ongoing Requirements Still in Effect

While new elements have been added, the following core requirements continue to apply:

• Remote Work Reporting: Employers must report whether employees work onsite, remotely from within California, or remotely from outside the state.

• Penalties for Noncompliance: The CRD may impose civil penalties of $100 per employee for an initial failure to file, and $200 per employee for subsequent violations. Submissions using outdated templates or missing required data may also be deemed noncompliant.

  
  

Next Steps for Employers

To minimize risk and ensure compliance, employers should:

• Confirm whether the reporting obligation applies to their business based on 2024 workforce data;

• Collect and verify demographic and compensation information, including remote work locations and relevant labor contractor data;

• Use the CRD’s updated templates and reporting tools, as outdated forms will not be accepted;

• Consult the 2024 CRD Handbook and User Guide to ensure accuracy and completeness in submission.

  
  

If your organization has questions about the reporting process or would like assistance reviewing your filings, please contact our Managing Partner, Richard Liu, at contact@consultils.com for tailored guidance and support.

Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions.

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As Managing Partner at ILS, Richard Liu ranks among the leading U.S. attorneys in corporate, employment, and regulatory law. He is known for crafting legal strategies aligned with clients’ business objectives and advising Fortune 500 companies, startups, and executives on corporate transactions, financing, privacy, and employment matters across the technology, healthcare, and financial sectors.

Before founding ILS, Richard practiced at top defense firms, where he developed a reputation for anticipating risks and designing strategies that balance protection with growth. He has secured favorable outcomes in contract and intellectual property disputes, represented clients in state and federal courts, and is recognized for combining large-firm expertise with boutique-firm agility. Richard is also a frequent speaker at industry and legal conferences.

Email: contact@consultils.com | Phone: 626-344-8949