California employers covered by the state’s pay data reporting requirements are reminded that annual pay data reports to the California Civil Rights Department (CRD) were due May 13, 2026. Employers that have not yet submitted their reports should act quickly to complete their filings. 

California law requires private employers with 100 or more payroll employees, including employers with labor contractor employees, to annually submit pay, demographic, and workforce data to the CRD. Reports are submitted through the CRD’s online Pay Data Portal and include workforce demographic information, pay bands, hours worked, and median and mean hourly rates by race, ethnicity, and sex. 

For those that have not yet filed, immediate action is important. Failure to submit required reports may expose employers to mandatory civil penalties for noncompliance. Employers who fail to report could face penalties of $100 per employee for initial failure to file and $200 per employee for any subsequent failure to file. 

SB 464 also introduced several important compliance updates that employers should prepare for moving forward. Effective January 1, 2026, demographic information collected for pay data reporting purposes must be stored separately from employee personnel records. Beginning in 2027, employers will transition from the current 10 EEO-1 job categories to 23 Standard Occupational Classification (SOC) categories for reporting purposes. 

In addition, the CRD’s current reporting cycle includes expanded reporting fields such as exemption status, employment type, and weeks worked during the reporting year. 

If your organization has not yet filed, consider taking these important next steps: 

1. Submit overdue reports immediately. Employers that missed the May 13 deadline should complete filings through the CRD Pay Data Portal as soon as possible. 
2. Review internal data collection practices. Confirm payroll, HR, and labor contractor data are accurate and complete. 
3. Separate demographic reporting data from personnel files. Ensure that internal procedures are SB 464 compliant by collecting and storing demographic information used for pay data reporting separately from employee personnel records. 
4. Prepare for expanded reporting categories. Begin evaluating how employees will be classified under the upcoming SOC job category structure, which becomes effective in 2027. 
5. Coordinate with labor contractors and payroll providers. Ensure reporting systems and vendor partnerships support current and future compliance obligations.