The CRD's annual filing requirement just got more complex. Here's what changed, what's required, and how to avoid a portal rejection.
The California Civil Rights Department (CRD) requires annual pay data filings from covered private employers — and the May 13, 2026 deadline for reporting year 2025 is approaching. For many payroll teams, this filing has historically meant exporting raw data, manually restructuring it to match the CRD's specifications, and hoping the portal accepts it. For reporting year 2025, that process just got harder.
This article covers who has to file, what the report requires, what's changed for this cycle, and how payroll teams can reduce the risk of a portal rejection.
Two categories of private employers are subject to California's pay data reporting law:
The 100-employee threshold is based on total headcount, not California-only headcount. An employer with 95 employees in Texas and 10 in California crosses the threshold and must file. If you meet both thresholds, you're required to submit two separate reports — each with its own template and field structure.
This article focuses on the Payroll Employee Report. Staffing companies and other employers using labor contractors should note that the Labor Contractor Employee Report carries separate requirements and its own filing complexities.
The quick answer: The California pay data report requires covered employers to report workforce demographics, pay bands, job categories, and hours data for a single snapshot pay period between October 1 and December 31 of the reporting year. Employees are grouped by establishment, EEO-1 job category, race/ethnicity, sex, pay band, exemption status, and employment type. Each group must include mean and median hourly rates and total hours worked. The report is submitted through the CRD's online portal by the second Wednesday of May each year.
Here's a closer look at what goes into the report:
The report is submitted via the CRD's online portal, either through manual data entry or by uploading a data file that matches the current-year template specifications.
CRD introduced three new mandatory fields for the 2025 reporting cycle. These fields apply to both the Payroll Employee Report and the Labor Contractor Employee Report, and they affect how employee groups are constructed — meaning more rows, more data validation, and more ways for a submission to fail.
Every California employee must now be classified as exempt or nonexempt under California's Industrial Welfare Commission wage orders and/or the federal Fair Labor Standards Act. Previously, exempt and nonexempt employees were grouped together. Now they're split, which creates more granular employee groupings and adds a compliance dimension: misclassification issues that were buried in headcount data now show up directly in the CRD submission.
Employers must now classify each employee as full-time, part-time, or intermittent. The "intermittent" category is new and applies to employees who work periodically or irregularly. For industries with variable-hour workers — staffing, healthcare, construction — this is not a trivial field to populate accurately.
In addition to total hours, employers must now report total weeks worked for each employee group during the reporting year. This includes weeks where the employee was on paid leave. The CRD requires whole-number reporting, and methodology choices around partial weeks are left to the employer — but should be documented for consistency.
Each of these fields increases the number of distinct employee groupings in the report. More groupings mean more rows to validate, more calculations to run, and more fields for the portal to reject if they don't conform to the current-year template structure.
$100 per employee
Mandatory penalty for first-time failure to file — and courts are now required to impose it. Senate Bill 464, signed October 2025, removed judicial discretion on CRD filing penalties.
The pay data report isn't hard because the concept is complicated. It's hard because the data lives in multiple systems.
Accurately completing the report requires pulling from payroll (W-2 earnings, hours), HR (job categories, demographic classifications, establishment assignments), and timekeeping (weeks worked, employment type verification). Those systems don't always agree, and the CRD's portal cross-checks totals against uploaded file data — inconsistencies produce upload errors.
There are also structural requirements that aren't obvious from looking at the form. The portal expects a specific file format with exact field names, precise code values, and current-year column structures. Submissions built from last year's template or restructured manually from a raw export are the most common source of portal rejections.
These are the most common points of failure in CRD pay data submissions:
For payroll teams managing this manually, each of these issues can mean hours of rework — and in some cases, a rejected submission with no time to resubmit before the deadline.
Greenshades now includes a California Payroll Employee Report, generated directly from your payroll system as a downloadable .xlsx file formatted to the CRD's current reporting-year specifications.
Here's what the report handles automatically:
After downloading, a small number of fields not stored in Greenshades will need to be completed before portal submission — including NAICS codes, major activity descriptions, any missing job category assignments, and a review of observer-perception demographic groupings. These are noted clearly in the output so nothing is missed.
The result: a report that's structured to the current-year CRD template, built from your actual payroll data, with a clear audit trail for your review before you upload.
For reporting year 2025, the filing deadline is May 13, 2026 — the second Wednesday of May. This deadline applies to both the Payroll Employee Report and the Labor Contractor Employee Report. CRD does not offer automatic extensions, and courts are now required to impose penalties for failure to file on time.
Private employers with 100 or more payroll employees — anywhere in the U.S. — must file a Payroll Employee Report if at least one of those employees works in California. The threshold is based on total headcount, not California-specific headcount. Employers using 100 or more labor contractor workers with at least one in California must also file a separate Labor Contractor Employee Report.
Under Senate Bill 464, signed into law in October 2025, courts are now required to impose penalties for failure to file. The penalty is $100 per employee for a first failure and $200 per employee for subsequent failures. This is a change from prior law, which gave courts discretion on whether to impose penalties. Timely filing should be treated as a hard compliance deadline.
The Payroll Employee Report covers workers directly employed by your organization. The Labor Contractor Employee Report covers workers supplied through a third-party labor contractor who perform work in your usual course of business. Each report uses a different template, has separate field requirements, and must be submitted independently. If your organization meets both thresholds, you're required to file both.
Greenshades generates your CRD-ready report directly from your payroll data so you don't to spend time manually mapping data.
Request A DemoNote: This information is for informational purposes only and does not constitute formal tax, legal, or compliance advice. Always consult with qualified tax advisors, legal counsel, and your organization's internal teams for guidance specific to your situation. Additional regulations may apply. For the most accurate and up-to-date information, refer to official government resources and regulatory agencies.