California Pay Data Reporting

Due May 8, 2024

California pay data reporting is upon us again. This year’s deadline, for both Payroll Employee and Labor Contractor Employee reports, is May 8th , 2024.


California has added new reporting requirements this year, though they are relatively minor. We have outlined below the existing and new filing requirements for this year’s reporting.


Who Must File?


California requires employers with 100 or more employees, nation-wide, and with at least one employee in California, file a Payroll Employee Report annually. This includes any remote employees who are physically located in California or reside outside of California but report into a California establishment.


In addition, employers who were provided with 100 or more workers by an agency or other third party (labor contractor) in 2023, and at least 1 of those workers were in California, must also file a Labor Contractor Employee Report.


What is Reported


Both Payroll Employee and Labor Contractor Employee Reports, have the same requirements.


  • A single pay period be selected between October 1st and December 31st , 2023 to determine which employees are to be included in the report.
  • The report will group employees by:

   a. Establishment

   b. Pay band

   c. EEO-1 category; and

   d. Race/Ethnicity and sex.

  • W2 Box 5 earnings and total hours for 2023 are used to determine the mean and median hourly wages of each group.

a. Establishment

b. Pay band

c. EEO-1 category; and

d. Race/Ethnicity and sex.


New Requirements for 2024


While the reporting obligations have remained primarily unchanged, there have been a few updates to reporting requirements this year.


  • Both report templates and pay bands have been updated for 2024.
  • Remote Employees for both Payroll Employee and Labor Contractor Employee Reports a. New data fields have been added to the reporting template which will require employers to report how many employees work remotely at each establishment during the snapshot period.
  • Labor contractors are no longer able to file reports with “unknown” for race/ethnicity or gender.


To provide guidance to employers, the California Civil Rights Department (CRD) released updated report templates, User Guide and FAQs, and earlier this week opened the Reporting Portal.


If you have any questions about California Pay Data Reporting or would like assistance with this year’s filing, please contact the Silberman Law professional with whom you work with.

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