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Chris Patrick is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. and is a member of the Firm’s Affirmative Action Compliance and OFCCP Defense practice group and Pay Equity resource group.

Chris partners with employers on practical solutions to ensure equal employment opportunity (EEO), including counseling on affirmative action, pay equity and transparency, and diversity. In short, Chris develops actionable strategies under privilege that identify and eliminate unseen barriers to EEO in personnel practices—often informed by trends in employee data.

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

In 2022, the California legislature passed Senate Bill (SB) 1162, which expanded the state’s existing pay data reporting requirements for “payroll employees” to include a new pay data report for employers with 100 or more “labor contractor employees.”  Under SB 1162, the pay data reporting deadline was moved to May. This year these reports

This year, employers in California have updated pay data reports to submit to the state’s Civil Rights Department (CRD).  Senate Bill (SB) 1162, passed in 2022, updated previous employee pay data reporting obligations and created an entirely new obligation to pay data reporting related to “employees hired through labor contractors.”  This year, these pay

When Senate Bill (SB) 1162 was signed in 2022, much of the focus was on the new pay transparency requirements. However, the bill also amended pay data reporting requirements in California. Under the amendments covered employers would need to submit separate pay data reports for employees hired through labor contractors. In addition, reporting would need

On September 27, 2022, California Governor Gavin Newsom signed Senate Bill (SB) 1162, which requires certain employers to provide more pay transparency on pay scales and expands pay data reporting obligations for other employers. The new obligations take effect on January 1, 2023.

Pay Transparency

Previously, under California law, employers had to provide an