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California pay data reporting and pay transparency
Pay data reporting and pay-scale disclosure have different coverage tests and purposes. Employers should review each obligation separately, then organize payroll and workforce records around the applicable instructions.
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General information, not legal or tax advice.
Review the annual reporting population
CRD identifies private employers with 100 or more payroll employees and private client employers with 100 or more labor-contractor employees as reporting groups. Its FAQ requires at least a California employee and counts employees inside and outside the state, including those on leave. Have counsel review coverage before excluding a related entity.
Sources: CRD - California Pay Data Reporting; CRD - 2025 Pay Data Reporting FAQ
Confirm the report year and calendar
CRD’s verified page lists May 13, 2026 for Reporting Year 2025. The FAQ describes the recurring deadline as the second Wednesday in May and submission through the Pay Data Portal. Check the current official reporting page for the next cycle rather than carrying a prior year’s date into a new checklist.
Sources: CRD - California Pay Data Reporting; CRD - 2025 Pay Data Reporting FAQ
Treat affiliated-entity coverage as a legal question
CRD notes that employers below the headcount threshold can be covered when affiliated entities form an integrated enterprise. The FAQ expressly describes that determination as a legal question. Prepare an entity and workforce overview for counsel instead of deciding from a single payroll account.
Sources: CRD - 2025 Pay Data Reporting FAQ
Check pay scales in recruiting and employee requests
DIR says employers with 15 or more employees must include a position’s pay scale in job postings, including third-party postings. Employees can request the scale for their position, and applicants can request it reasonably. Coordinate HR’s approved scales with payroll records so inconsistent labels are identified.
Sources: DIR Labor Commissioner - Equal Pay Act and Pay Transparency FAQ
Retain the job and wage history
DIR states that job-title and wage-rate history must be kept during employment and for three years afterward. Maintain an effective-date history when titles or rates change. Limit access to workforce data and document which reviewed extract was used for the reporting package.
Sources: DIR Labor Commissioner - Equal Pay Act and Pay Transparency FAQ
Sources: workforce reporting and pay scales
Prepare payroll data for the employer’s review
Tidwell helps organize payroll records and exports. The employer and counsel determine coverage and oversee HR compliance decisions.