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

California’s annual pay data reporting submission this year is due on May 13, 2026.  Each cycle, the California Civil Rights Department (CRD) typically releases updated guidance for that year’s reporting in early February. 

While we await this annual guidance, CRD has already provided preliminary templates for payroll employee and labor contractor pay data reporting

Recently, in Mora v. C.E. Enterprises, Inc., the California Court of Appeal upheld a trial court’s decision in favor of an auto dealership alleged to have used an improper “piece rate” or “flag hours” compensation model.

Two former service technicians alleged that the dealership’s compensation system violated requirements for compensating for productive and non-productive

California’s pay data reporting rules are now more burdensome.

Senate Bill 464, signed into law on October 13, 2025, enhances existing pay reporting requirements to address wage disparities. It introduces strict changes for private employers, effective in 2026 and 2027, including stricter penalties and reporting on new job categories.

Current Reporting Rules

Private employers

California’s Department of Finance recently announced the minimum wage increase for 2026. The minimum wage in California will increase from $16.50 per hour to $16.90 perhour on January 1, 2026. This increase applies to all employers, regardless of size. This increase is based on the state’s annual cost-of-living adjustment tied to the U.S. Consumer Price Index

California Governor Newsom recently signed Senate Bill (SB) 648, which authorizes the state’s Labor Commissioner to investigate and issue a citation or file a civil action for gratuities taken or withheld in violation of the Labor Code. This enforcement authorization will take effect January 1, 2026.

The Labor Code defines wage theft as employers