The California Civil Rights Department (CRD) has released updated guidance for the 2024 pay data reporting cycle. While most of the reporting requirements remain unchanged from last year, a key modification includes the addition of a new racial/ethnicity category — Middle Eastern or North African (MENA). Employers need to be aware of these changes to ensure compliance with California’s strict reporting mandates. The deadline for submitting the 2024 pay data report is May 14, 2025.
To ensure compliance with these new regulations, please contact our team at contact@consultils.com for expert advice and support.
Key Changes
1. Introduction of the MENA Category
The most notable update for 2024 is the inclusion of the MENA category in employee demographic reporting. This change aligns with the U.S. Office of Management and Budget’s (OMB) revised Statistical Policy Directive No. 15. The category covers individuals with origins in Middle Eastern or North African countries, such as Lebanon, Iran, Egypt, Syria, Iraq, and Israel.
Employers should report employees in this new category if the data is available. If not, they may continue using prior guidance, which classifies individuals of Middle Eastern and North African descent under the "White" race/ethnicity category. Employees’ self-identification is the preferred method for determining race/ethnicity, but in cases where employees do not voluntarily provide this information, employers must rely on employment records, other reliable sources, or observer perception as a last resort.
2. Other Minor Modifications
The former "Two or More Races" category is now "Multiracial and/or Multiethnic."
The word "Other" has been removed from the "Native Hawaiian or Other Pacific Islander" category, leaving it as "Native Hawaiian or Pacific Islander."
Reporting Requirements
Despite the updates to race/ethnicity categories, many aspects of the pay data reporting process remain consistent with the 2023 reporting cycle. Employers should take note of the following:
Reporting Deadlines: The deadline for submitting the 2024 pay data report is May 14, 2025. The platform opened for new filings on February 3, 2025.
Who Must Report: Employers with 100 or more employees, including those hired through labor contractors, must submit a pay data report. These reports must detail workforce demographics, pay, and other employment data.
Penalty for Non-Compliance: Failure to comply with pay data reporting requirements may result in fines of up to $100 per employee for the first offense and $200 per employee for subsequent violations.
Labor Contractor Reporting: Covered employers must file separate labor contractor employee reports. Labor contractors must provide data that attributes their employees to the client employer establishments where they work.
Pay Bands and Remote Workers: The 12 pay bands from 2023 remain the same for 2024, and employers must continue reporting remote employees, specifying whether they work inside or outside of California.
New Employer Resources
For the first time, CRD has released a 2024 California Pay Data Reporting Handbook, a comprehensive 23-page guide detailing reporting requirements and filing instructions. Additionally, the California Pay Data Reporting Portal – User Guide serves as a standalone document with step-by-step instructions for completing both Payroll Employee and Labor Contractor Employee Reports. These resources are designed to assist employers in complying with California's pay data reporting mandates.
How Employers Should Prepare
Employers should take the following steps to ensure compliance with the updated pay data reporting requirements:
Review Employee Demographic Data: Determine whether existing records include MENA classification and update data collection processes accordingly.
Familiarize with the 2024 Handbook and Reporting Instructions: Utilize the newly available resources for a smoother filing process.
Coordinate with Labor Contractors: Ensure labor contractors provide the required data to meet reporting obligations.
Meet the Filing Deadline: Avoid penalties by ensuring all required reports are submitted by May 14, 2025.
Conclusion
California continues to lead the way in advancing pay equity and workforce transparency. The 2024 pay data reporting updates provide a more inclusive framework for racial and ethnic identity while maintaining rigorous reporting standards. Employers must proactively address these changes to ensure compliance and avoid potential penalties. If you need assistance navigating the updated requirements, our law firm is here to help guide you through the process efficiently and effectively.
To ensure compliance with these new regulations, please contact our team at contact@consultils.com for expert advice and support.
Disclaimer: The materials provided on this website are for general informational purposes only and do not, and are not intended to, constitute legal advice. You should not act or refrain from acting based on any information provided here. Please consult with your own legal counsel regarding your specific situation and legal questions.
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