California Pay Data Reporting

Private employers with 100 or more employees and at least one employee based in California are required to file the California Pay Data Report. This report is due on May 14, 2025. DCI can assist your organization in filing this report. From raw data to final submission, our experienced consultants are here to help!

Who must submit?

Private employers with 100 or more employees, regardless of location or whether they are full-time, with at least one employee based in California must submit this report.     

What must be submitted?

  • Wage data on employees in each EEO-1 Category by sex, race, and ethnicity using W-2 information. Wage data must be reported within 12 pay bands. 

  • Median and mean hourly rate for each combination of race, ethnicity, and sex, within each of the 10 EEO-1 job categories. 

  • Hours worked during the reporting year for each of these employees.

  • A separate report must be submitted on persons hired through “labor contractors.” A labor contractor is defined as an “individual or entity that supplies, either with or without a contract, a client employer with workers to perform labor within the client employer’s usual course of business.” The report on persons hired through labor contractors must include the same information as the report on regular employees. 

Who must be included in the report?

All California employees and employees who report to a California establishment must be included in the report. 

Updates to California’s Pay Data Reporting  

In September of 2022, changes to California pay data reporting were signed into law. 

  • Employers with multiple establishments are now required to submit a report covering each establishment instead of a consolidated report. 
  • Employers must report on median and mean wages within each EEO-1 category. 
  • Employers must report on persons hired through “labor contractors.” 
  • The deadline for submitting the California Pay Report was moved from March 31 to the second Wednesday in May. 
  • Courts can impose civil penalties not exceeding $100 per employee for the first failure to file a report and not exceeding $200 per employee for subsequent failures to file a report. 
  • If a company fails to file a complete and accurate report because a labor organization failed to provide them with the required pay scale information, the law states that an “appropriate amount of penalties” will be applied to the labor organization for failure to provide such information. 

Our Consulting Services

We assist our clients in complying with the California Pay Data Reporting Law and other state-specific requirements. While some of the requirements in the California Law are new, we have been filing California Pay Data Reports since the original law, took effect. We can file this report on behalf of your organization and conduct pay equity analyses to help predict what the Civil Rights Department of California may find in your pay data.

California Pay Data Reporting Resources

Infographic: What Employers Need to Know about California's New Pay Data Reporting Requirements
A - CA Pay Series Small
What you need to know about California's Pay Data Reporting Law.
B - Eligibility Small
Private employers with 100 or more employees in the United States and at least 1 employee based in California must submit this report.
C - Employee Reporting Small

All employees physically in California and all U.S employees who report to a California establishment must be included in the report.

D - Labor Contractor Reporting Small
A private employer that has 100 or more employees hired through labor contractors must submit a separate pay report including the same data for employees.
E - Disclosure Requirements Small
Employers must provide pay scale information to applicants and employees upon request in certain circumstances.  Many employers must include pay scale information in job postings.
F -  Penalties for Not Filing Small
Courts can impose penalties for not filing the required report or failing to disclose pay scale information.
G - 3 Tiers Small
DCI recommends a 3-tiered analysis using tests of statistical significance that evaluate the W-2 wage data required in the report.

For assistance with the California Pay Data Report, contact us