Compliance | CA Equal Pay Reporting

October 02, 2026 17:35

AviontéBOLD supports California's Equal Pay Reporting requirements, helping staffing agencies meet their obligations under California Senate Bills 464 and 642. These laws require covered employers and labor contractors to submit annual pay data to California's Civil Rights Department (CRD), and AviontéBOLD provides the tools to generate and export the required report data directly from your system.

Note: California's Equal Pay Reporting requirements apply to private employers and labor contractors with 100 or more employees. Staffing agencies typically qualify as labor contractors and must provide pay data to their client employers for inclusion in the employer's annual CRD filing. Reports for the 2025 reporting year are due by May 13, 2026.

Overview and Legal Background

California requires covered private employers to submit an annual pay data report to the Civil Rights Department (CRD). This requirement was significantly expanded in 2025 through two new laws effective January 1, 2026:

SB 464 — Strengthens the annual pay data reporting obligation. Employers must report employee pay data categorized by race/ethnicity, sex, job category, pay band, exemption status, and employment type. New 2026 reporting fields include exemption status, employment type (full-time, part-time, or intermittent), and total weeks worked during the reporting year. Mandatory penalties now apply for failure to file.
SB 642 — Expands California's Equal Pay Act to prohibit pay disparities based on gender (including non-binary genders), broadens the definition of "wages" to include bonuses, stock, expense reimbursements, and more, and extends the statute of limitations for equal pay claims to three years.

For staffing agencies, compliance has two components. First, agencies are considered labor contractors and must provide pay data for any employees placed with a client employer who has 100 or more total employees. Second, agencies that directly employ 100 or more employees must also file a Payroll Employee Report for their internal staff.

Note: Beginning with the 2026 reporting cycle (reports due May 2027), employers must classify workers using 23 Standard Occupational Classification (SOC) job categories instead of the 10 EEO-1 categories used previously. AviontéBOLD will be updated to support this expanded classification framework ahead of that deadline.

Who This Applies To

California's pay data reporting requirements apply to your agency if any of the following are true:

Situation	Reporting Obligation
Your agency has 100 or more employees on its own payroll	File a Payroll Employee Report for your internal workforce
Your agency places workers with a California client employer who has 100 or more total employees	Provide a Labor Contractor Employee Report with pay data for those placed workers
Both of the above	File both report types

Note: The 100-employee threshold is based on the client employer's total headcount — not just the workers placed by your agency. If your client has 100 or more employees across all sources, you are required to provide pay data for your placed workers.

Report Data Fields

The CA Pay Data Report captures the following information for each employee group (aggregated by race/ethnicity, sex, job category, pay band, exemption status, and employment type):

Field	Description	2026 Update
Race/Ethnicity	EEO-1 race/ethnicity category for each employee	No change
Sex	Reported gender (male, female, non-binary)	Non-binary now included
Job Category	EEO-1 job category (10 categories through 2026; 23 SOC categories starting 2027)	No change for 2025 reporting year
Pay Band	Annual earnings range (12 standard pay bands defined by CRD)	No change
Exemption Status	Whether the employee is exempt or non-exempt under minimum wage/overtime rules	New for 2026
Employment Type	Full-time, part-time, or intermittent	New for 2026
Total Annual Weeks Worked	Aggregated weeks worked during the reporting year, including paid leave	New for 2026
Total Hours Worked	Aggregated hours worked by all employees in each group	No change

Note: California requires that demographic data collected for pay data reporting be stored separately from employees' personnel records. AviontéBOLD handles this separation within the system. Consult your legal counsel regarding your organization's specific data storage policies.

Accessing the CA Pay Data Report

The CA Equal Pay Reporting feature is available to users with the appropriate permissions in AviontéBOLD.

Navigation

Log in to AviontéBOLD.
Navigate to [Menu Path — e.g., Reports > Compliance > CA Equal Pay Reporting].
The CA Equal Pay Reporting page opens, displaying your available reporting options.

Permissions

Access to the CA Equal Pay Reporting feature requires the following permission:

Permission	User Type
[Permission Name — confirm from AzDO card]	[User Type — e.g., Admin, Back Office Manager]

Generating and Exporting the Report

AviontéBOLD compiles your pay data report using employee records, payroll data, and demographic information stored in the system. Once generated, the report can be exported in the format required for CRD submission.

Step 1: Set Your Reporting Parameters

Select the Reporting Year for the data you are compiling (e.g., 2025 for the report due May 2026).
Select your Report Type:
- Payroll Employee Report — for employees on your agency's direct payroll
- Labor Contractor Employee Report — for workers placed with client employers
If running a Labor Contractor Employee Report, select the Client Employer from the available list.

Placeholder: Reporting parameters screen for CA Equal Pay Report

Step 2: Review and Validate Data

Click [Button Name — confirm from AzDO card] to generate a preview of the report data.
Review the data for completeness. AviontéBOLD will flag any employees with missing required fields such as race/ethnicity, sex, exemption status, or employment type.
Correct any flagged records before proceeding to export.

Note: The CRD does not accept "unknown" values for demographic fields on Labor Contractor Employee Reports. Ensure that race/ethnicity and sex are populated for all placed employees before generating your final export.

Step 3: Export the Report

Once data has been validated, click [Export Button — confirm from AzDO card].
Select your preferred export format. The CRD requires submission via their online portal using the official CRD Excel template.
Save the exported file and use it to complete your CRD filing.

Placeholder: Export options for CA Equal Pay Report

Submitting to the CRD

AviontéBOLD generates the data needed for your filing, but submission is completed directly through California's Civil Rights Department portal. Here's how the process works end-to-end:

Generate your report in AviontéBOLD using the steps above and export the data.
Access the CRD Pay Data Reporting Portal at calcivilrights.ca.gov/paydatareporting. The portal opens in February each year.
Upload your data using the CRD's official Excel template. Map your AviontéBOLD export to the CRD template columns as needed.
Submit by the deadline — the second Wednesday of May each year (May 13, 2026 for the 2025 reporting year).

Note: If your agency provides workers to multiple California client employers, you may need to submit a separate Labor Contractor Employee Report for each client. Coordinate with your clients early to confirm their filing requirements and share your pay data in a timely manner.

Frequently Asked Questions

Does this apply to all of our California placements?

The requirement applies when the client employer (not just your agency) has 100 or more total employees. If a California client has 100 or more employees — including workers from all sources — you are required to provide pay data for the employees you place with that client.

What happens if we don't file?

Under SB 464, courts are now required (not just permitted) to impose civil penalties for failure to file. Penalties are up to $100 per employee for a first failure and up to $200 per employee for each subsequent failure. Labor contractors can also face penalties for failing to provide required data to a filing employer.

What are the new employment type categories for 2026?

Employees must now be classified as one of the following for pay data reporting purposes: Full-Time, Part-Time, or Intermittent (employees who work periodically or do not regularly work full- or part-time hours). AviontéBOLD maps to these categories based on employment records in the system.

How does AviontéBOLD handle the demographic data storage requirement?

California's SB 464 requires that demographic data collected for pay data reporting be stored separately from employee personnel records. AviontéBOLD maintains this separation within the system. Contact your Avionté account team if you have questions about your specific data configuration.

When will AviontéBOLD support the 23 SOC job categories?

The expanded 23 Standard Occupational Classification (SOC) job categories are required beginning with the 2026 reporting cycle (reports due May 2027). AviontéBOLD will be updated to support SOC-based classification ahead of that deadline.

Where can I find the official CRD filing templates?

The California Civil Rights Department publishes official templates and guidance at calcivilrights.ca.gov/paydatareporting. Final operative templates for each filing year are released in February when the CRD portal opens.