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California's 2024 Pay Data Reporting: What Employers Need to Know

Updated: Apr 26

The California Civil Rights Department (CRD) released updated guidance for the 2023 pay data reports, due by May 8, 2024. It is crucial for California employers to stay informed about the recent changes. Here's a comprehensive update to guide you through the evolving landscape.

For additional information about pay data reports, please contact our Head of Corporate Transaction, Fiona Xu, at

pay data report

Key Dates and Resources

  • Portal Opening: Employers can start submitting their pay data reports on February 1, 2024.

  • Submission Deadline: All reports must be submitted by May 8, 2024.

  • New Templates: The CRD has provided updated Microsoft Excel templates to aid in compiling the necessary information for this year’s reporting.

Who Needs to Report Pay Data

  • ​​Private employers with 100 or more employees, including those outside California, are required to report pay data if they have at least one employee working in or living in California. Employers with multiple establishments in California must submit a report for each location.

  • Employers with 100 or more employees hired through labor contractors in the previous year are required to submit a separate Labor Contractor Employee Report. This report should detail the workers hired through labor contractors, including the contractors' ownership names.

California pay data reporting portal

Detailed Reporting Instructions

Employers must provide comprehensive pay data, including:


  1. A separate report for labor contractor employees, reflecting similar data points as the standard employee report: labor contractor details, establishment, job category, race/ethnicity, and sex of each employee group.

  2. Additional data for each employee group on:

    1. The number of employees in the group working onsite

    2. The number of employees in the group working remotely from California

    3. The number of employees in the group working remotely outside of California

  3. Calculation and submission of mean and median hourly rates, requiring analysis of hourly rates, pay bands, job categories, and demographic information.

Penalties for Non-Compliance

Failing to submit the required reports can lead to penalties starting at $100 per employee, increasing to $200 for subsequent violations. These penalties also apply to labor contractors who delay providing necessary pay data.


Strategies for Compliance

  • Engage Early with Labor Contractors: Begin collecting pay data from labor contractors as soon as possible. Given the broad definition of labor contractors, which can include roles like janitorial services, it's vital to understand who needs to be included in your reporting.

  • Audit for Pay Discrepancies: The detailed reporting requirements are likely to highlight pay discrepancies. Employers should proactively analyze pay data, identify any disparities, and rectify them before submitting their report. This process not only ensures compliance but also fosters a fairer workplace.

  • Prepare Your Data: With the portal opening on February 1, 2024, employers should start preparing their data in advance, utilizing the CRD’s updated templates and resources for guidance.

For additional information about pay data reports, please contact our Head of Corporate Transaction, Fiona Xu, at

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Fiona Xu

Fiona Xu, Esq. is the Partner and Head of Corporate Transaction of ILS. She works with clients in a wide range of industries and at all stages of their life cycles. She helps companies maximize the value of their strategic relationships and the return on their equity investments, both domestically and internationally.

Email: | Phone: 626-344-8949

*Disclaimer: This article does not constitute legal opinion and does not create any attorney-client relationship.


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