California pay data reports for Reporting Year 2025 are due May 13, 2026 to the Civil Rights Department (CRD). If you are a private employer with 100 or more payroll employees, or a private client employer with 100 or more labor-contractor workers, you must file annually under Government Code §12999 — and 2026 is the year the rules get stricter.
Who Must File
- Payroll employee report: Private employers with 100+ payroll employees (inside or outside California, but reporting on California employees)
- Labor contractor employee report: Private client employers with 100+ workers hired through labor contractors in California
- Establishment-level reporting: Data broken out by establishment, pay band, job category, race, ethnicity, and sex — similar to federal EEO-1 but filed separately with CRD through its portal and Excel templates
You cannot satisfy California's requirement by filing only the federal EEO-1. CRD requires its own filing even as EEOC considers ending federal EEO-1 collection.
What Is New for 2026, What Changes in 2027
For the May 2026 filing (2025 data), CRD has released preliminary templates and FAQs signaling expanded tracking of employee classifications and work patterns, plus stricter validation. The core pay-band structure (10 job categories) still applies for 2025 data.
Starting with reporting for 2026 data (due in 2027), SB 464 expands the job-category structure from 10 to 23 categories and makes penalties for non-reporting mandatory when CRD requests them — a shift from discretionary to required enforcement. Employers who wait until 2027 to rebuild their HRIS categories will be re-mapping under deadline.
What to File — and How
CRD's portal requires Excel templates by report type (payroll vs. labor contractor), with each establishment as a separate section. Demographic data comes from voluntary self-identification; pay data uses W-2 Box 5 (Medicare wages) mapped to pay bands. Hours worked and new work-pattern fields must be consistent with payroll records.
The most common filing error is establishment count mismatch — headquarters plus each physical or remote-entity establishment must be reconciled to the payroll system's worksite file. A California employer with 120 employees across three offices files three establishment sections, not one rolled-up total.
Penalties and Record-Keeping
Beginning in 2026, courts must impose penalties if CRD seeks them for failure to file — prior law made penalties discretionary. CRD has also emphasized data storage obligations: maintain the pay and demographic data and filing records for at least three years after submission, and be prepared to produce them on audit.
Late or inaccurate filings can also surface in pay-equity and hiring audits that CRD conducts from the pay-data set itself.
Bookkeeping and HRIS Checklist Before May 13
- Reconcile headcount on the snapshot period CRD prescribes (typically a single pay period between Oct 1–Dec 31, 2025) to payroll, not to HR headcount that includes leaves.
- Validate race/ethnicity/sex data against voluntary self-ID forms; do not impute.
- Map pay bands from Box 5 wages and reconcile band totals to payroll totals — a band-total variance is a filing rejection.
- Document labor-contractor data separately, with contractor name and worker count per establishment.
In Beancount, keep pay-data filing dates and covered-establishment lists as dated notes so the May 13 deadline recurs with the right scope each year.
Simplify Your Financial Management
Pay data reporting turns HR demographics into audited financial-record territory. Beancount.io keeps payroll, establishment, and demographic source postings version-controlled — so the totals you file tie directly to the W-2s you issued. Get started for free and make May 13 a submission, not a scramble.