If you file California pay data reporting and your payroll data includes contractors and expanded demographic fields, the template you used last year will be rejected this May.
What Expanded
California's Civil Rights Department (CRD) expanded the pay data reporting template for 2026 to align the labor-code pay data (Labor Code 432.3) with the privacy law's expanded coverage:
- Who is reported: Not just full-time W-2 employees, but also 1099 contractors who work a significant portion of hours in California, if they meet the reporting threshold (100+ payees in many cases).
- What is reported: The old 10 pay bands are now 12, with the top band split. Hours and pay are reported by establishment, by job category, and now by an expanded combined race/ethnicity and sex field that matches the privacy law's data inventory.
Covered employers: Private employers with 100+ employees and/or 100+ workers hired through labor contractors in the prior calendar year, with at least one California payee. The threshold counts contractors, not just employees.
May Filing, Privacy Law Overlap
The pay data report is due the second Wednesday in May. In 2026, CRD's template cross-validates against the California Privacy Rights Act (CPRA) data inventory: the demographic fields in the pay data must match the categories you disclose in your privacy notice for the same workforce.
That means the payroll and the privacy inventory must come from the same source-of-truth, not from two spreadsheets that diverge in April.
Bookkeeping That Survives the Report
- Pay grouping: Every payee's W-2 Box 1 or 1099 gross pay, hours (or exempt proxy hours), establishment, and job category must be taggable. If your payroll system can't tag by establishment and contractor vs. employee, export and add the tags before the template.
- Hours for exempt and contractors: Exempt hours are proxied at 40 per week for full-time; contractors' hours are tracked via invoices or time reports, not via payroll hours, which they don't have.
- Privacy vs. payroll reconciliation: The count of individuals by demographic category in the pay data must reconcile to the privacy inventory's workforce count. Keep a single workforce census that feeds both.
Keep Your Finances Organized From Day One
Pay data reporting is payroll reporting with a civil rights overlay. The employers who file cleanly are the ones whose payroll, contractor ledger, and privacy inventory come from one census, version-controlled and ready in April, not May.
Beancount.io keeps that census as plain text — every payee as a transaction with establishment, category, and demographic — ready before the template is due. Get started for free and make May a filing, not a reconstruction.