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Quick Hits
- The deadline for filing 2024 California pay data reports is May 14, 2025.
- California requires that covered employers file payroll employee and labor contractor employee reports.
- Both reports require demographic information, pay data, and work hours for covered employees and labor contractor employees.
With less than a month left to complete the 2024 pay data filings, employers with a presence in California may want to note that the filing threshold for these reports is low, such that having a single payroll employee working remotely in California may require the filing of the payroll employee report.
Specifically, an employer with one hundred or more W-2 employees working anywhere in the United States, with at least one employee working in California, is required to file a payroll report. Likewise, an employer with one hundred or more labor contractor employees anywhere in the United States, with at least one working in California, is required to file the labor contractor report. More specifics on the jurisdictional requirements and definition of a California employee/labor contractor employee can be found here.
Based on the enactment of Senate Bill No. 1162 in 2022, the Civil Rights Department (CRD) of the State of California can now seek civil penalties of $100 per employee against an employer that fails to file a required report. The penalties increase to $200 per employee for a subsequent failure to file a required report. CRD is also entitled to recover its costs in any enforcement action. For an employer with a sizeable California workforce, these penalties could be significant.
Employers that have not completed their 2024 pay data filings may want to begin preparations by gathering the necessary information so that they can complete an on-time filing by May 14. More information about the 2024 filings, including changes, can be found here and here.
Ogletree Deakins’ Government Contracting and Reporting Practice Group will continue to monitor developments with respect to California pay data reporting and will provide updates on the firm’s California, Government Contracting and Reporting, and Pay Equity blogs as additional information becomes available.
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