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Unraveling the Latest Updates in California's 2024 Pay Data Reporting Requirements

By Debra Milstein Gardner - Feb 7, 2024 12:53:21 PM - 5 MINS READ

California employers need to gear up for the latest enhancements in pay data reporting in 2024. The state has once again fine-tuned its reporting requirements to promote fair pay and equal opportunities. The reporting portal opened February 1, 2024, and the submission deadline looms on May 8, 2024. It is crucial for California employers to stay informed about the recent changes. Here's a comprehensive update to guide you through the evolving landscape.

Who's Affected?

If your company has a workforce of at least 100 employees or 100 or more workers hired through labor contractors and has a presence in California, you are in the reporting spotlight. Labor contractors are defined as individuals or entities that supply workers to a client employer to perform labor within their normal course of business. This can be done with or without a contract.

What's New?

In response to the evolving work landscape, employers are now required to report the number of employees working remotely. The definition of "remote worker" is specific, covering those entirely remote with no expectation of regular in-person reporting to a physical establishment during the reporting period.

What Do California Employers Need to Do? 

Employers must file a separate Labor Contractor Employee Report covering workers hired through a labor contractor in the previous calendar year. The report mirrors the payment employee template, requiring the same essential data points for each labor contractor, establishment, job category, race/ethnicity, and sex employee group.

This year's payroll template introduces three crucial data points for each employee group:

1. The number of employees in the group working onsite
2. The number of employees in the group working remotely from California
3. The number of employees in the group working remotely outside of California

Employers are required to calculate and report the mean and median hourly rates for payroll employees and labor contractor employees. Detailed calculations are necessary, involving individual hourly rates, pay bands, job categories, and demographic factors such as race/ethnicity and sex.

Failure to file a required report can result in penalties of up to $100 per employee, escalating to $200 per employee for subsequent violations. These penalties apply not only to employers but also to labor contractors failing to provide timely pay data to client employers. The California Civil Rights Department (CRD) is authorized to recover its enforcement costs.

Updated Microsoft Excel templates are now available, simplifying the compilation and submission process. 

California employers have resources for assistance. The California Pay Data Reporting FAQs are posted for your review; however, there is a pending update to reflect the 2023 changes. These OutSolve resources are also helpful to understand more about California's pay transparency laws and annual pay reporting:




As the 2024 California Pay Data Reporting Portal opens, be diligent in adhering to the updated requirements. With the new templates, additional data points, and potential FAQ updates on the horizon, employers are urged to act promptly to prepare their data. Stay proactive in understanding and meeting these reporting obligations to contribute to the state's goal of achieving fair and equal pay practices.

OutSolve can assist you in filing you annual pay reports and guide you through the process. 

Debra Milstein Gardner

Debra Milstein Gardner has worked in the Equal Employment Opportunity (EEO) and Affirmative Action (AA) space for the past 43 years while working in the public and private sectors in various human resources compliance roles. She began her career working for the Equal Employment Opportunity Commission and then went to the Marriott Corporation for nine years working in EEO, Affirmative Action and field human resource roles. In 1990, Debra founded Workplace Dynamics LLC providing EEO, AA, and DEI consulting services to government contractors. In 2016, Debra sold the affirmative action portion of Workplace Dynamics to OutSolve LLC and works part-time as a Market Analyst. Debra is a sports fanatic, routing for the Baltimore Ravens and all Virginia Tech Hokie teams. She loves to hike and boat in her mountain and lake community of Lake Lure, NC.

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