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All private employers who have 100 or more employees, with at least one California employee
Effective Date:
May 13, 2026 (reporting due). See details below.
Summary:
The California Civil Rights Department has published final versions of pay data reporting templates for the 2025 reporting year. The templates include new data fields for reporting employees’ exemption status, employment type, and weeks worked during the reporting year.
Next Steps:
Covered employers should use the final version of the templates and file their pay data reports by May 13, 2026.
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The Details
The California Civil Rights Department (CRD) has published final versions of pay data reporting templates for the 2025 reporting year. The templates include new data fields for reporting employees’ exemption status, employment type, and weeks worked during the reporting year.The CRD has provided accompanying guidance, including answers to frequently asked questions, a user guide and a handbook for employers to review for help with completing the templates.
Background
Under California law, a private employer with 100 or more employees, including at least one California employee, must submit a pay data report covering the prior calendar year to the state on or before the second Wednesday of May each year, which for 2025 reporting is May 13, 2026.
A private employer that has 100 or more employees, with at least one California employee, hired through labor contractors within the prior calendar year must also submit a separate pay data report to the state covering those employees. The private employer must also disclose on the pay data report the ownership names of all labor contractors used to supply employees. A labor contractor must supply all necessary pay data to the private employer.
New Data Fields in Templates
As mentioned above, the templates include new data fields for reporting employees’ exemption status, employment type, and weeks worked during the reporting year. The following is the CRD’s guidance for completing these fields.
Reporting Exemption Status
The guidance says covered employers should identify whether each California employee is exempt from the minimum wage and overtime pay provisions of state laws and/or the federal Fair Labor Standards Act. Employers should classify each California employee as having either:
· Exempt status; or
· Non-exempt status.
Reporting Employment Type
The guidance says covered employers should classify each California employee into one of three employment types:
· Full-time: An employee who is assigned to regularly work full-time hours under the employer’s standard or alternative workweek schedule would fall under the “full-time” employment type.
· Part-time: An employee who is assigned to regularly work less than full-time hours under the employer’s standard or alternative workweek schedule would fall under the “part-time” employment type.
· Intermittent: An employee who is assigned to periodically or irregularly work full-time or part-time hours, under the employer’s standard or alternative workweek schedule, would fall under the “intermittent” employment type.
Reporting Weeks Worked
The guidance says covered employers should identify the number of weeks worked by each California employee during the reporting year. This includes weeks during which the employee was on any form of paid time off (such as vacation time, sick time, or holiday time).
For each establishment, covered employers should identify the number of California employees in each employee group by classifying employees based on race/ethnicity, sex, job category, pay band, exemption status, and employment type.
Once a covered employer has identified the employee group for each of its California
employees in the snapshot period, the employer should then aggregate the total weeks
worked during the reporting year for all the California employees in the same employee
group. The resulting number should be entered as the Total Annual Weeks Worked.
If an employee doesn’t share the same employee group of any other employee in the
establishment, the employer would report a count of one employee and report the number
of weeks worked during the reporting year by that employee alone.
In reporting on labor contractor employees, weeks worked includes the actual number of
weeks worked by the labor contractor employee for the reporting client employer.
Next Steps
Covered employers should use the final version of the templates and file their pay data reports by May 13, 2026.
At this time, the California Pay Data reporting templates are expected to be available during the first week of April. We recommend planning your internal data preparation accordingly to avoid delays. ADP will communicate when the templates are live so you can promptly access the system and complete your reporting. We understand navigating through new regulations can be challenging. If you are unsure and need additional support, please call our dedicated line at 877.310.0825 Option 2 or send us an email at hrotaxuiclaims@adp.com. A member of our team will be happy to assist with any questions.
Note: If you are required to file a pay data report for labor contractors, you must follow a similar process for your labor contractor employee report and submit it through the portal separately from your payroll employee report.