Ashley Holsey, SPHR, PHR
If you employ people in California, it’s that time of year again. Pay Data Reporting is the state’s annual homework assignment—required, important, and surprisingly manageable if you start preparing early.
Why It Matters
Under SB 464, private employers with 100 or more employees, including those working through labor contractors, are required to submit annual pay data reports. Employee counts are based on headcount, not full-time equivalents, and include all individuals employed during a single pay period selected between October 1 and December 31 of the reporting year, regardless of hours worked. Reports must be submitted to the California Civil Rights Department (CRD) by the second Wednesday in May and include:
- Employee counts by race, ethnicity, and sex across 10 job categories (expanding to 23 categories in 2027).
- Employee earnings within the Bureau of Labor Statistics (BLS) pay bands, plus hours worked.
- Mean and median hourly pay rates by race, ethnicity, and sex.
- Additional fields for 2026 reports include exemption status, employment type (full-time, part-time, intermittent), and weeks worked.
New Requirements and Risks in 2026
- Demographic data must be stored separately from personnel files.
- Failure to file triggers mandatory civil penalties: up to $100 per employee for the first failure, $200 per employee for subsequent failures, which may include labor contractors responsible for missing data.
Preparing Now for 2026 and Beyond
Although the May 13, 2026, deadline may seem distant, meaningful preparation takes time. Employers should:
- Begin collecting 2025 data, including exemption status, employment type, and weeks worked;
- Review job classifications and start mapping roles to the expanded 23 Standard Occupational Classification (SOC)-based categories for 2027;
- Validate compensation data and ensure demographic information is collected and stored separately from personnel files; and
- Document processes and align reassignments with other reporting obligations to reduce compliance risk.
Early planning not only minimizes penalties but also positions organizations to address pay equity proactively, rather than reactively.
Bottom Line
SB 464 raises the bar for California pay data reporting by expanding requirements, increasing enforcement, and reinforcing the state’s commitment to pay equity. Compliance is now more than just an annual exercise, it is an ongoing HR and governance priority. With the right preparation and coordination, this homework assignment can be completed efficiently and even help your organization strengthen pay practices.
The portal for CA Pay Data Reporting can be found at https://pdr.calcivilrights.ca.gov/s/ and is expected to open in early February 2026. For more information, you can also review the FAQs for 2025 which is available at https://calcivilrights.ca.gov/paydatareporting/faqs/
Please also stay tuned for the annual EEO-1 Reporting Requirements and Deadline.