The California Civil Rights Department (CRD) has issued new resources to assist employers in preparing for the 2024 pay data reporting cycle. For the first time, the CRD has released a California Pay Data Reporting Handbook, providing employers with a structured and user-friendly guide for completing their reports. This marks a significant change from previous years when employers had to rely solely on Frequently Asked Questions (FAQs) and other guidance documents.
Background
California’s pay data reporting requirements were established under Senate Bill 973, enacted in 2020. This law requires private employers with 100 or more employees, including those hired through labor contractors, to submit annual reports to the Civil Rights Department. The reports must include pay and demographic data for California workers based on a designated “snapshot period” to ensure compliance with pay equity regulations.
In 2022, Senate Bill 1162 expanded these requirements to explicitly cover workers hired through labor contractors. Under California law, employers must file their pay data reports annually, with the deadline for the 2024 reporting year set for May 14, 2025.
The report must include:
- Employee Demographic Information – Employers must collect race, ethnicity, and sex data based on the required categories.
- Pay Data – Employers must calculate and report the mean and median hourly rate of payroll employees and/or labor contractor employees, categorized by establishment, job category, pay band, race/ethnicity, and sex.
- Hours Worked – Employers must report the total hours worked by each employee within the reporting year.
Employers may select a “snapshot period”, provided it is a single pay period within the timeframe of October 1 to December 31 of the reporting year.
Key Changes for the 2024 Reporting Cycle
The 2024 reporting cycle introduces several updates, including a new racial/ethnic category, a pay data reporting handbook, and new instructional materials designed to improve clarity and accessibility.
- New Racial/Ethnic Category – California’s updated guidance adds a new racial/ethnic category for 2024 reports: “Middle Eastern or North African” (MENA).
- Pay Data Reporting Handbook – One of the most notable updates is the introduction of the 2024 Pay Data Reporting Handbook. This 23-page handbook provides comprehensive guidance on pay data reporting requirements, including clear instructions on employer eligibility, submission procedures, and required reporting elements. Unlike FAQs, which can sometimes be difficult to navigate, the handbook presents information in a structured and user-friendly format.
- New Instructions Document – Another key change for 2024 is how reporting instructions are provided. Previously, instructions for completing payroll and labor contractor employee reports were embedded as tabs within the reporting templates. Now, these instructions have been moved to separate 10-page documents, providing a more detailed and comprehensive explanation. The new instruction documents include:
- An overview of the reporting process;
- Step-by-step filing guidance;
- Requirements for single-establishment and multiple-establishment reporting; and
- Detailed explanations of each data column, including data types and character limits.
Next Steps for Employers
To ensure compliance and a smooth filing process, employers should:
- Review the Handbook and Updated Instructional Materials – With the 2024 reporting cycle underway, now is the time for employers to review the new handbook and familiarize themselves with updated requirements. Taking the time to examine the revised instructions and ensuring that reporting teams are aware of the changes will help streamline the submission process.
- Assess Payroll and Labor Contractor Employee Data – Employers should assess payroll and labor contractor employee data to confirm that all necessary information is readily available and formatted correctly. Labor contractors are required to provide employers with the necessary data and information for submitting a Labor Contractor Employee Report. It is recommended that employers reach out to labor contractors as soon as possible to obtain this information.
- Review Frequently Asked Questions (FAQs) – While the new handbook is a valuable resource, the FAQs also contain important details that employers may need to reference.
Early preparation is essential to avoid last-minute challenges and ensure that all reporting obligations are met accurately and on time. By leveraging these updated resources, employers can navigate the 2024 pay data reporting cycle with greater confidence and efficiency.
How HR Works Can Help
HR Works offers Compensation & Pay Equity solutions that help employers stay compliant and ensure fair pay practices within their organization. Contact us to learn more about how we can assist you with meeting California’s wage disclosure requirements and reporting obligations.
