California Civil Rights Department Previews 2025 Pay Data Reporting Templates

Quick Hits

• The California Civil Rights Department’s preliminary pay data reporting templates for the 2025 pay reporting cycle show three new columns on both the payroll employee and the labor contractor employee reports: (1) Exemption Status; (2) Employment Type; and (3) Total Annual Weeks Worked.
• The preliminary templates show that these new columns are not required fields for the 2025 pay data reporting.
• The preliminary templates and FAQs are subject to revision, with final versions expected to be released when the filing platform opens in early February 2026.
• California pay data reports for Reporting Year 2025 are due by May 13, 2026.

Preliminary 2025 Templates

The preliminary templates for the 2025 payroll employee and labor contractor employee reports include three new columns: (1) Exemption Status; (2) Employment Type; and (3) Total Annual Weeks Worked. According to CRD, the preliminary templates “are subject to change and are intended for planning purposes only” and “should not be filed with CRD.” The preliminary FAQs explain the information to be provided for each column:

• Exemption Status: Employers should identify which employees are exempt from the California Industrial Welfare Commission wage orders and/or the federal Fair Labor Standards Act. If they are exempt, they should be marked with “Exempt” in this column. If not, they should be labeled as “Non-exempt.”
• Employment Type: Employers should classify each covered employee into one of three classifications: “Full-time,” “Part-time,” or “Intermittent.” The FAQs explain that an employee who is “assigned to regularly work full-time hours under the employer’s standard or alternative workweek schedule” is a “Full-time” employee, while an employee who is assigned to regularly work less than full-time hours is a “Part-time” employee. An “Intermittent” employee is one who is “assigned to periodically or irregularly work full-time or part-time hours, under the employer’s standard or alternative workweek schedule.”
• Total Annual Weeks Worked: Employers should count each week in which a covered employee worked and also include any week during which the employee was on any form of paid time off, such as vacation, sick time, or holidays.

The three new columns do not have an asterisk, indicating they are not required for 2025 reporting at this point. Instead, these columns are currently optional for the 2025 reporting. The FAQs do not explicitly state that these columns are optional, but, without using words such as “shall,” “must,” or “required,” they state that employers “should” provide information in each column. It is possible that these columns will remain as optional columns for the 2025 reporting cycle but become mandatory for future pay reporting cycles.

Next Steps

The FAQs state that CRD will release the final or “operative” reporting templates when the 2025 pay data filing platform opens in early February 2026, along with updated FAQs, a handbook, a user guide, and other resources. The final reporting templates will indicate whether the three new columns still appear and, if so, whether they are required or optional. If the columns are optional, employers will be able to choose whether to provide the requested information or leave those columns blank. If the columns are required, employers must complete each column for all reported payroll and labor contractor employees.

At this point, the indication is that the new columns will be optional for the 2025 reporting cycle. However, these columns may become mandatory at some point. If that happens, CRD will hold even more information on the classification and pay characteristics of California employees, which it can use to analyze the pay practices of California employers.

Ogletree Deakins’ Government Contracting and Reporting Practice Group and Workforce Analytics and Compliance Practice Group will continue to monitor California pay data reporting developments and will provide updates on the firm’s California, Government Contracting and Reporting, Pay Equity, and Workforce Analytics and Compliance blogs as additional information becomes available.

In addition, the Ogletree Deakins Client Portal tracks developments and provides real-time updates on California’s employment laws. Full law summaries are available for Premium-level subscribers. Snapshots and Updates are available for all registered client users. For more information about the Client Portal or to inquire about a Client Portal subscription, please contact us at clientportal@ogletree.com.

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