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

The deadline for employers to comply with California’s pay data reporting requirement (Senate Bill 973) and submit pay data to the Department of Fair Employment and Housing (DFEH) is March 31, 2021.

The DFEH has launched an information page that provides needed clarity on certain obligations and has issued additional guidance on the

With the future of the EEOC’s pay data collection efforts unclear, California’s effort to legislate its own race- and sex-based pay data reporting requirements likewise has stalled, for now.

Since July, California’s Senate Bill 171 (requiring private employers with at least 100 employees to submit an annual report of employee pay data broken down by

The recent focus on the EEOC’s new Component 2 to its EEO-1 Report has been undeniable. It requires employers report on the race, ethnicity, sex, job type, pay, and hours worked data of its employees.

OMB approved this data collection during the Obama Administration. Then, under President Donald Trump, the OMB reversed course, staying the