This is an update to our previous alert on this year’s California Pay Data Reporting.

The California Pay Data Reporting Portal is now open and employers have until Wednesday May13th, 2026 to submit their Payroll Employee and Labor Contractor Reports to the California Civil Rights Department (CRD).

To coincide with the opening of the Reporting Portal, the CRD also released the finalized Report Templates, Frequently Asked Questions, and Handbook to assist employers’ with their California Pay Data Reports.

California has made certain changes to the reporting requirements this year, which we outline below.

Who Must File?

California requires employers with 100 or more employees, nationwide, and with at least one employee in California, to file a Payroll Employee Report. This includes employees who:

1. Physically work at a location in California;
2. Are remote/home-based employees who are physically located in California; or
3. Reside outside of California but report into a California location.

In addition, employers who were provided, nationwide, with 100 or more workers by an employment agency or other third party (Labor Contractor) in 2025, and at least one of those workers were physically located in California, or reported into a California location, must also file a Labor Contractor Employee Report.

Expanded Reporting Requirements for 2026

California has confirmed the changes for this year for both Payroll and Labor Contractor Employee Reporting –

1. Payroll and Labor Contractor Employee Report templates and pay bands have been updated for 2026.
2. Employers must use the updated templates. The Reporting Portal will reject submissions using prior year versions of the templates.
3. Whether employees are exempt or non-exempt.
4. Whether employees are full-time or part-time.
5. Total number of weeks an employee worked in 2025.
6. Total hours worked in 2025 remains a reporting requirement as well as weeks worked.

What is Reported?

Both Payroll Employee and Labor Contractor Employee Reports have the same reporting requirements:

1. A single pay period is selected between October 1 and December 31, 2025 to determine which employees are to be included in the report.
2. The data required to be reported for employees and labor contractor employees includes –
3. Establishment
4. Pay Band
5. EEO-1 Job Category
6. Race/Ethnicity and Sex
7. Mean and Median Hourly Wage of Similarly Grouped Employees**
8. Remote Employees Located Within California
9. Remote Employees Located Outside of California
10. Exempt/Non-Exempt Status*
11. Full-Time/Part-Time Status*
12. Total Hours Worked in 2025 (Including PTO and Sick Leave Hours)
13. Weeks Worked in 2025 (Including PTO and Sick Leave Hours)*

* New Reporting for 2026 Submissions

** W-2 Box 5 earnings and total hours worked in 2025 are used to determine an employee’s “California Hourly Wage” and then the mean and median hourly wages of each group.

*   *   *   *

For Silberman Law clients with California Pay Data Reporting obligations, we will follow up with you regarding next steps.

If you have questions about California Pay Data Reporting or would like help with this year’s reporting, please contact the Silberman Law professional with whom you work, or simply reply to this Employer Alert.