Okay. One more thing to add to your “to do” list…
California employers of 100 or more employees (and/or 100 or more workers hired through labor contractors) must report 2024 pay, demographic, and other workforce data to the Civil Rights Department (CRD) by May 14, 2025. To submit the annual report, employers must access the online portal by visiting the California Pay Data Reporting page.
New Resources
The CRD’s webpage provides links to FAQs and a new handbook that contains filing instructions for employers. Additionally, the site links to updated versions of the pay data reporting Excel templates and CSV examples and provides new instructions for those templates and examples. We love the instructions! They provide employers detailed guidance to ensure they properly complete the Payroll Employee Reports and/or Labor Contractor Employee Reports.
One important detail: Excel templates and CSV examples from prior years will not be accepted; CRV will reject any reports submitted on outdated versions of these documents.
New Race/Ethnicity Requirement
In response to the White House Office of Management and Budget’s (OMB) changes to a directive relating to race and ethnicity data, California now requires a new race/ethnicity category to be added to pay data reporting – “Middle Eastern or North African” (MENA).
According the CRD handbook, MENA refers to “[i]ndividuals with origins in any of the original peoples of the Middle East or North Africa, including, for example, Lebanese, Iranian, Egyptian, Syrian, Iraqi, and Israeli.”
Because MENA is a new category, for Reporting Year 2024, employers have the option of reporting race and/or ethnicity of MENA employees following OMB’s 2024 standards if this information is available or continuing to report MENA following prior guidance based on EEOC’s instructions for reporting race/ethnicity on the EEO-1 survey.
Prior Changes Still in Effect
The following changes to the CRD’s process, which were made prior to this year, remain in effect:
- Employers must report whether employees worked remotely during the “Snapshot Period.”
- For Labor Contractor Employee Reports, reporting “unknown” race/ethnicity or sex of a labor contractor employee no longer is permitted.
- A private employer with 100 or more workers hired through labor contractors in the prior calendar year (with at least one worker based in California) must file a separate Labor Contractor Employee Report that covers workers hired through labor contractors in the prior calendar year.
- Employers must calculate and report the mean and median hourly rate of its payroll employees and/or labor contractor employees, by establishment, job category, pay band, race/ethnicity, and sex.
- CRD may seek a monetary penalty against any employer that fails to file a required report, as well as against any labor contractor that fails to supply necessary data to a client employer. As an example, CRD provides a link to a settlement in a case where the employer failed to provide pay data.
- In the pay data report, employers must report on their workers assigned to California establishments and/or working within California. Employers may not report on workers located outside of California and or who are assigned to an establishment outside of California.
Next Steps
Employers should prepare their pay data reports using CRD’s new and updated resources and submit their reports by the May 14, 2025, deadline. You can contact the CRD at PayDataReporting@calcivilrights.ca.gov with any questions.
