California’s Civil Rights Department (CRD) has released new FAQs and preliminary templates previewing substantial additions to the 2025 pay data reporting cycle. These updates introduce new data fields, expand employee grouping requirements, and increase the complexity of reporting for both payroll employees and labor contractor employees.

2025 Payroll Employee Reports and Labor Contractor Employee Reports are due May 13, 2026.

Below are key changes and practical steps to support compliance with pay data reporting.

The CRD has added three new mandatory data elements for the 2025 reporting cycle:

1. Exemption status
2. Employment type
3. Weeks worked during the reporting year

These fields apply to all California payroll employees and labor contractor employees, and significantly expand the data employers must track and aggregate.

1. Exemption Status

Employers must now classify each California worker as either:

Exempt, or Non‑exempt under California’s Industrial Welfare Commission wage orders and/or the federal Fair Labor Standards Act.

Why this matters:

• Exempt and non‑exempt employees will no longer be grouped together.
• Employee groups must now be defined by race/ethnicity, sex, job category, pay band, exemption status, and employment type.
• This change will increase the number of employee groupings and the complexity of data validation.

Employers should review exemption classifications now to ensure accuracy and consistency across systems.

2. Employment Type

CRD now requires employers to assign each California employee to one of three employment types: Full‑Time, Part‑Time, or Intermittent

Key considerations:

• Many HR systems do not currently distinguish “intermittent” employees.
• Hybrid, variable‑hour, or on‑call roles may require re‑evaluation.
• Employers should ensure these classifications are consistently applied across payroll, HRIS, and labor contractor data.

3. Weeks Worked

For the first time, employers must report total weeks worked during the reporting year for each California employee.

This includes:

• Weeks worked
• Weeks on paid time off (vacation, sick leave, holidays)

After employees are grouped by all required characteristics, employers must report Total Annual Weeks Worked for each group. If a group contains only one employee, the individual’s weeks worked must be reported. For labor contractor employees, weeks worked must reflect actual weeks worked for the reporting client employer.

Because this metric requires annual aggregation, employers should confirm that timekeeping and payroll systems can accurately capture and sum weeks worked across the year.

Next Steps for Employers:

The new data fields will significantly increase the administrative burden of California’s May 2026 pay data reporting cycle. Employers should begin preparing now by:

• Updating HRIS and Payroll Systems
  • Ensure systems can track exemption status, employment type, and weeks worked.
  • Validate that these fields can be exported and aggregated for reporting.
• Reviewing and Standardizing Employee Classifications
  • Confirm exemption status classifications are accurate and well‑documented.
  • Evaluate how “intermittent” status applies to variable‑hour or hybrid roles.
• Coordinating With Labor Contractors
  • Confirm contractors can provide exemption status, employment type, and weeks worked.
  • Establish timelines and data‑quality expectations to avoid delays.