California Pay Data Reporting – Updates for 2025 Filing Cycle

The California Civil Rights Department (CRD) has posted updated FAQs regarding the preliminary versions of the 2025 Pay Data Reporting templates that have been posted to the CRD’s website. The preliminary versions of the templates have not yet been finalized by the CRD; however, the FAQs point to new data fields that will be required for this filing cycles.

The new data fields that will need to be reported for the 2025 Reporting cycle are: Employees’ Exemption Status, Employment Type, and Weeks Worked during the Reporting Year. These new fields are required for both the employee pay reports and the labor contractor reports. The FAQs do give guidance on how each one of the new fields should be reported:

• Employees’ Exemption Status - This field should identify if the California employee is exempt from the minimum wage and overtime pay provisions of the California Industrial Welfare Commission wage orders and/or the federal Fair Labor Standards Act (exempt / non-exempt).
• Employment Type – This filed should identify if the California employee falls within one of the three categories: Full-Time, Part-Time, or Intermittent. Definitions of each category are dependent upon the employer’s standards.
• Weeks Worked during reporting year – This field should identify the number of weeks worked by each California employee during the reporting year (including weeks of paid time off in any form – vacation time, sick time, or holiday time). For each establishment that is being reported, the employer should identify the number of California employees in each group created by classifying employees based on the following:
  • Race/Ethnicity
  • Sex
  • Job Category
  • Pay Band
  • Exemption Status
  • Employment Type

Once employee groups are identified, the employer should then aggregate the total weeks worked during the reporting year for all California employees in the same employee groups (the resulting number would be added as the Total Annual Weeks Worked). For employees that do not share the same employee group of other employees in an establishment, the employee would report a count of one employee and report the number of weeks the employee worked alone.

For labor contractor employees, the weeks worked is the actual number of weeks worked by the labor contract employee for the reporting client during the snapshot period.

The full list of FAQs on the Pay Data Reporting Preliminary Templates (as well as the preliminary templates) is now available. Final versions of all pay data reporting resources for the 2025 filing cycle are scheduled for release in February. Berkshire will be able to help our clients navigate these new reporting requirements.

If you are new to using our California Pay services and are interested, you can request more information on our State & Local Reporting Services.

Stayed tuned for any further updates from the CRD regarding the 2025 filing cycle.