California generally uses the strict “ABC Test” to determine if a worker is an employee or an independent contractor. Under the ABC Test, a worker is presumed to be an employee unless the hiring company proves that the worker should instead be classified as an independent contractor. The ABC Test has been codified into law

Employers in the entertainment industry know that payroll compliance can be uniquely complicated. Production schedules change, wrap dates move, and crew members may be hired for short stints across multiple projects.

California has a special final pay statute aimed at this reality: Labor Code section 201.5, which sets rules for when and how final wages

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