California Pay Data Reporting Deadline: What Employers Need to File by May 14, 2025

What Changed

Under California's Senate Bill 1162 (SB 1162), private employers with 100 or more employees — including workers hired through labor contractors — must annually submit pay, demographic, and workforce data to the California Civil Rights Department (CRD). The filing deadline for the 2024 reporting year is May 14, 2025 (the second Wednesday of May).

SB 1162, signed into law in 2022, expanded California's existing pay data reporting requirements by:

Adding a separate report for workers hired through labor contractors
Requiring reporting of median and mean hourly rates by race, ethnicity, and sex within each job category
Expanding data collection for remote workers to capture their assigned work location
Introducing civil penalties for employers who fail to file

Employers file through the CRD's online portal, which also provides a reporting handbook, user guide, and downloadable templates.

Who Is Affected

This requirement applies to:

Private employers with 100 or more employees (including part-time employees)
Private employers with 100 or more workers hired through labor contractors
Employers must file a separate report for direct employees and for labor contractor workers

Public employers, employers with fewer than 100 employees, and sole proprietors without employees are exempt from this filing requirement.

For multi-state employers, the report must include data for all employees working in California, regardless of where the employer is headquartered.

Where It Applies

California statewide. The reporting obligation applies to any employer with employees performing work in California, including remote workers whose assigned work location is in the state. Employer headquarters location is irrelevant — what matters is where the work is performed.

When It Takes Effect

The filing deadline for the 2024 reporting year is May 14, 2025. Going forward, the deadline falls on the second Wednesday of May each year.

Employers who have not yet filed should note that the CRD's online portal is the only accepted submission method. Paper filings are not accepted.

Why It Matters

California uses pay data reports to identify potential pay discrimination and target enforcement actions. The CRD has been increasingly aggressive in analyzing submitted data for disparities across race, ethnicity, and sex within job categories.

Penalties for non-compliance are significant:

First failure to file: Up to $100 per employee
Subsequent failure to file (after the CRD seeks a court order compelling compliance): Up to $200 per employee

For an employer with 500 employees, that is a potential exposure of $50,000 to $100,000 in penalties alone — before any pay equity enforcement actions that might result from the CRD's analysis of the data.

This law is part of California's broader pay transparency push, which also includes salary range disclosure requirements in job postings and upon employee request. Employers who are not already conducting internal pay equity audits should view this filing as a prompt to do so — if the CRD finds disparities in your data, they will come knocking.

The Humareso Take

If you have 100 or more employees in California and have not yet filed, this is a same-day priority. The deadline is not flexible, and the CRD has made clear that they treat non-filers seriously. Beyond the filing itself, we strongly recommend using this as an annual trigger to run your own internal pay equity analysis before the state does it for you. It is far better to identify and address disparities proactively than to receive a letter from the CRD asking why your data shows a pattern. We have seen the reporting process catch employers off guard — especially the labor contractor report, which many overlook entirely.

Recommended Action Steps

File your 2024 pay data report through the CRD's online portal immediately if you have not already done so — the deadline is May 14, 2025.
Prepare a separate labor contractor report if you engage 100 or more workers through staffing agencies or labor contractors performing work in California.
Verify your data accuracy before submission — ensure job categories, pay bands, and demographic data are correctly mapped using the CRD's reporting templates.
Conduct an internal pay equity audit using the same data you are reporting to identify and remediate any compensation disparities before the CRD reviews your submission.
Document your reporting process and retain copies of submitted reports for your records in the event of a CRD inquiry.
Contact your Humareso representative for assistance with pay data report preparation, labor contractor report requirements, or a proactive pay equity review.