The California Civil Rights Department (CRD) has released its Reporting Year (RY) 2025 Pay Data Reporting FAQ and Handbook. The statute remains familiar, but the filing mechanics this cycle are not.  CRD’s materials emphasize a prescribed file structure, add required data elements, and signal that conformity to the current-year template will be central to a successful submission.

Filings are due May 13, 2026.

Quick background

California’s pay-data program requires covered employers to report workforce counts by job category, race/ethnicity, sex, and pay band. The RY 2025 materials do not change that foundation. As we previewed, they do, however, revise the schema filers must use and add data elements that affect how records are grouped and summarized for submission.

Key changes

1. Employee groups: two added classification dimensions.

For RY 2025, CRD’s Handbook and FAQ treat employee groups as the combination of job category, race/ethnicity, sex, pay band — and now, exemption status and employment type. The practical effect is additional group splits and more granular rows, particularly where exemption status and employment type are not consistently recorded at the individual-employee level.

2. Total Annual Weeks Worked is now an item in the file.

For RY 2025, CRD requires a numeric Total Annual Weeks Worked for each employee-group row. The Handbook defines weeks worked as weeks an employee worked during the reporting year and explicitly includes weeks in which the employee was on paid leave. The upload specifications require whole-number reporting (including rounding of the group total). The Handbook does not prescribe a single, uniform approach to partial weeks; that methodological choice remains with filers and may warrant documentation.

3. Additional guidance on remote workers.

For PY 2025, instead of noting whether employees “worked remotely during the Snapshot Period” the RY 2025 guidance requires three establishment-and-group counts:

• employees not remote;
• employees remote within California; and
• employees remote outside California.

The guidance also makes clear that the “remote outside California” count is reportable only for California establishments; non-California establishments are to enter zero in that field. For multi-state employers, that constraint can affect aggregation logic and establishment mapping.

4. Race/ethnicity categories incorporate OMB’s MENA change.

CRD’s 2024 FAQ language allowed employers to report Middle Eastern and North African race/ethnicity (MENA) consistent with OMB’s 2024 standards, where available; the RY 2025 Handbook updates that direction, stating employers should report MENA as a category separate from “White,” consistent with OMB’s revised standards. However, the new materials address reporting categories and classification for filing; they do not expressly require employers to modify self-identification collection processes or to resurvey workforces to capture a new category. Whether and how to collect MENA-identifying data remains an operational decision.

5. Labor-contractor scope: “usual course of business” described in operational terms.

As a helpful tool, the Handbook describes “usual course of business” using a functional lens: recurring, routine work tied to regular operations is more likely to be treated as in scope, while isolated or one-off tasks are less likely to be. The language helps frame the vendor-supplied labor analysis in broad strokes but still leaves the individualized determination up to the reporting parties.

What is unchanged (select items)

• The statutory 100+ employee threshold remains the coverage trigger.
• Pay-band placement continues to rely on W-2 wages (Box 5, with Box 1 fallback).
• Sex categories remain female/male/non-binary, with self-identification framed as the preferred source.
• Payroll employees and labor contractor workers continue to be submitted on separate reports using different templates.

Reading the Handbook defensibly

The Handbook functions primarily as an operational filing guide and upload specifications. It tightens field-level rules (including whole-number and rounding requirements) and standardizes how certain elements are presented in the file. At the same time, it does not answer every implementation question—particularly around methodological choices (such as partial weeks) and fact-specific classifications (such as certain remote-work permutations or contractor-scope edge cases). Those choices may turn on documentation and internal consistency as much as on any single “right” answer.

Bottom line

RY 2025 is less about changing underlying statutory duties and more about changing the submission structure and required fields. For practitioners, the immediate focus is understanding what the new FAQ/Handbook requires in the file and spotting where existing systems or established reporting logic may not align cleanly with the RY 2025 schema.

If you have any questions about these requirements, or for assistance preparing this year’s filing, please contact Jackson Lewis.