Understanding the Differences Between California’s Pay Data Reporting Law and Federal EEO-1 Reporting Requirements
California’s pay data reporting law surpasses federal requirements by requiring detailed, establishment-specific information to address pay disparities. This law mandates private employers with 100 or more employees (with at least one employee in California) to submit annual data on their employees’ pay, hours worked, and demographics to the California Civil Rights Department (CRD). Collect the data from a single pay period during the previous 4th quarter. Submissions are due May 14, 2025.
In contrast, the federal EEO-1 report, mandated by the Equal Employment Opportunity Commission (EEOC), requires certain employers to provide a demographic breakdown of their workforce by race, ethnicity, gender, and job category.
Employers who meet both the EEO-1 requirements and the CA pay-data reporting requirements will need to file reports with both entities.
Key Differences:
- Scope of Reporting:
- California: Employers must report detailed pay data, including mean and median hourly rates, and hours worked.
- Federal: Focuses on demographic breakdown without detailed pay data.
- Reporting Structure:
- California: Requires separate reports for each establishment within the state.
- Federal: Allows for a consolidated report for all establishments meeting certain criteria.
- Applicability:
- California: Applies to all private employers with 100 or more employees with at least 1 working in CA, regardless of federal EEO-1 report filing.
- Federal: Applies to private employers with 100 or more employees and federal contractors with 50 or more employees, plus additional criteria that must be met to be considered a Federal Contractor.
Actions California Employers Need to Take:
- Identify Reporting Period:
- Select a single pay period during the previous 4th quarter to collect data (Oct. 1-Dec. 31).
- Gather Detailed Pay Data:
- Collect information on mean and median hourly rates, and total hours worked for each employee.
- Collect Demographic Information:
- Gather data on employees’ race, ethnicity, and gender.
- Prepare Establishment-Specific Reports:
- Create separate reports for each establishment within California.
- Submit Reports to CRD:
- Ensure all collected data is accurately reported and submitted to the California Civil Rights Department by May 14, 2025.
For more information on California’s pay data reporting requirements, visit the CRD website. For federal EEO-1 reporting requirements, refer to the EEOC website or our previous article for a quick rundown.
PEO Clients:
Contact your compliance specialist at Nextep for information on how we can help handle these filings and assist your company.
At Nextep, we’re here to help you keep up with these requirements and make sure your business remains compliant. Reach out to our compliance experts at compliance@nextep.com for personalized support and guidance.

