The California Civil Rights Department (CRD) has released preliminary versions of the pay data reporting templates for Reporting Year 2025. The filing deadline for Reporting Year 2025 will be May 13, 2026.
These templates, along with a detailed FAQ document, provide insight into the data fields and reporting format that will be required in the upcoming reporting cycle. Organizations that take the time now to familiarize themselves with the new requirements and prepare their HR information systems (HRIS), will be better positioned to submit accurate and timely reports when the filing system opens.
Key Changes in Reporting
Beginning with the Reporting Year 2025, pay data reports will need to include employees’ exemption status, employment type, and weeks worked during the reporting year.
- Exemption Status: This refers to whether employees are classified as exempt or non-exempt from the minimum wage and overtime pay provisions of the California Industrial Welfare Commission wage orders and/or the federal Fair Labor Standards Act. Each employee in the California report will need to be classified as “Exempt” or “Non-exempt.”
- Employment Type: The three reportable employment types are “Full-time,” “Part-time,” or “Intermittent,” aligning to the employer’s schedule. Each employee’s employment type effective during the pay period selected as the employer’s “snapshot period” should be reported.
- Weeks Worked During the Reporting Year: Employers will need to be able to identify and report on the number of weeks worked by each employee in the report during the reporting year. Weeks worked will include the actual number of weeks worked plus any weeks the employee was on any form of paid time off (such as vacation time, sick time, or holiday time).
Preliminary FAQ Document Released
In addition to the templates, the CRD has published a preliminary Frequently Asked Questions document. This document provides further guidance on reporting each of the new data fields as well as information about calculating “hours worked” for exempt and non-exempt employees.
Preparing for 2025 California Pay Data Reporting
Although the deadline for Reporting Year 2025 isn’t until May 13, 2026, the reportable data is effective between October and December of 2025. There are several steps organizations should take now to ensure a smooth and compliant reporting process.
- Assess Your Current Data: Evaluate your HRIS’s ability to report on the new data fields and the accuracy of the data within the system. Do you have an accurate record of each employee’s exemption status, employment type, and weeks worked in the system? If not, now is the time to update the information in preparation for the upcoming filing, ensuring proper effective dates to facilitate accurate reporting. If reporting capabilities are not in place currently, contact your HRIS vendor to ensure reporting will be available when needed.
- Stay Updated: Since the preliminary templates are subject to change, it’s important to stay up to date with any further guidance CRD provides. Keep an eye out for the official 2025 reporting guidelines, which will be released in February 2026, and be prepared to adjust your reporting as needed.
- Coordinate with Labor Contractors: The new data fields for 2025 reporting will be required for both Payroll Employee and Labor Contractor Employee reports. For employers that are using labor contactors, now is the time to have conversations with your labor contractor organizations to ensure that they will be prepared to report on the new data fields.
Final Thoughts
While these preliminary templates are not intended for submission until final versions of the templates are released in February 2026, they serve as a valuable tool for employers to prepare for upcoming California Pay Data Reporting requirements. It is important to note that the CRD has indicated that the 2025 preliminary templates are subject to change. However, employers taking the time to prepare now will be best positioned to meet the filing deadline on May 13, 2026.
The new data fields and report format are changes in addition to increased penalties for non-compliance, new data storage requirements, and expanded job categories announced earlier this year. It’s more important than ever that employers with 100 or more US employees and one or more California-based employee stay apprised of changes to the reporting requirements.
How HR Works Can Help
HR Works assists employers with California Pay Data Reporting, saving employers the administrative burden of completing the report in-house. To learn more about these services and how to leverage our compliance expertise and support, please contact us at info@hrworks-inc.com or call 1-877-219-9062.
