The California Civil Rights Department (CRD) has updated its Pay Data Reporting FAQs to announce that beginning April 18, 2023, it will begin accepting “enforcement deferral requests” from employers for their Labor Contractor Employee Reports due May 10, 2023.  

Once granted, CRD will defer – through July 10, 2023 – seeking an order of compliance for the employer to file its Labor Contractor Employee Report. Requests will only be considered by employers registered in CRD’s pay data reporting portal, and CRD will only accept requests submitted through the portal. 

In addition to the “Payroll Employee Report” that all private employers with 100 or more employees (with at least one employee based in California) must file, Senate Bill 1162 added the requirement that 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. An employer submitting a Labor Contractor Employee Report submits one report that covers labor contractor workers at all of the employer’s establishments. Senate Bill 1162 requires the employer’s labor contractors to provide necessary data and information to the employer submitting the report and requires the employer to identify their labor contractors. 

More information on Pay Data Reporting can be found on the CRD website and its Pay Data Portal.