CWC Updates California Pay Data Reporting Guide For 2025 Reporting Season

February 12, 2026

What's New

CWC has updated its California Pay Data Reporting Guide. The updated guide covers the rules for filing the 2025 report that is due May 13, 2026, and provides tips on the steps that a covered company should follow when pulling the required data.

New for the 2025 reporting cycle is the addition of three optional data fields:

1. “Employment Type” – full-time, part-time, or intermittent;
2. “Exemption Status” – exempt or non-exempt under the FLSA; and
3. “Total Annual Weeks Worked” – weeks worked in 2025, including PTO.

CWC has also included a sample communication template that members can provide to labor contractors when requesting information for the California labor contractor employee pay data report.

What It Means

Employers must use the new templates published by California’s Civil Rights Department and should confirm that internal data processes align with the data fields. Labor contractor reporting continues to present significant compliance challenges, particularly because CRD’s interpretation of “labor contractor employee” is broad and requires detailed demographic data. New mandatory penalties beginning in 2026 heighten the need for accurate reporting and timely submission.

What You Should Do

Review CRD’s updated website, Pay Data Reporting Portal, user guide, and FAQs to confirm that your systems can support the revised 2025 reporting requirements. CWC members should join our webinar on February 26, 2026 where we will provide an overview of the obligations and guidance on how to prepare for this cycle.

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