California recently amended its pay data reporting obligations, which require covered employers to submit employee and labor contractor pay data reports annually to the Civil Rights Department (CRD).
Under the amendment, starting in 2026: (1) employers must store demographic data separately from personnel records, and (2) penalties for failing to file pay data reports will become mandatory if CRD requests them. The amendment clarifies that an employer can be fined for a labor contractor’s failure to provide required data but that penalties may be shifted to the contractor.
The amendment also will replace the 10 EEO-1 categories currently used for classifying and reporting employee data with the 23 major groups in the Standard Occupational Classification (SOC) system, beginning with the May 2027 filing.
Members of the Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, can read more here.