24 California Pay Data Reporting Examples and Scenarios

The California Civil Rights Department (CRD) requires that certain employers report pay and hours-worked data by establishment, job category, gender, race, and ethnicity to the CRD annually. The Pay Data Reporting is required under CA Government Code section 12999, amended by Senate Bill 1162.

Due to the nature of this reporting, we’ve compiled a comprehensive assortment of Pay Data Reporting examples and scenarios with the intention of providing further information and instruction regarding reporting requirements.

General Pay Data Reporting Examples

California Pay Data Reporting - General Examples
General California Pay Data Reporting Examples

Important Definitions

  • Client Employer – A private individual or entity that has workers hired through Labor Contractors.
  • Employee – An individual on an employee’s payroll, and can include part-time employees. “Employee” may refer to a Payroll Employee, Labor Contractor Employee, or both.
  • Employer – A private individual or entity that is obligated to file a Pay Data Report on Payroll and/or Labor Contractor Employees.
  • Establishment – An economic unit producing goods or services.
  • Labor Contractor – An individual or entity that supplies a Client Employer with workers to perform labor within their usual course of business.
  • Labor Contractor Employee – An individual on a Labor Contractor’s payroll, including part-time workers, for whom the Labor Contractor is required to withhold federal social security taxes and who performs labor for a Client Employer within their usual course of business.
  • Labor Contractor Employee Report – A Pay Data Report in which a Client Employer annually reports data on their Labor Contractor Employees to the CRD.
  • Pay Data – The data that must be reported to the CRD.
  • Pay Data Report – A Payroll Employee Report and/or Labor Contractor Employee Report.
  • Payroll Employee – An individual on an employer’s payroll, including part-time individuals, for whom the employer is required to withhold federal social security taxes from that individual’s wages.
  • Payroll Employee Report – The type of pay data report in which an employer annually reports data on their Payroll Employees to the CRD.
  • Snapshot Period – A single pay period between October 1st and December 31st of the reporting year. It is only used to identify the Payroll Employees or Labor Contractor Employees that should be included in the report.

Which type of reporting is required?

In the columns below, we outline three Pay Data Reporting examples that go over when each type of reporting type would be required.


Payroll Employee
Report Only

Company A has 200 Payroll Employees in California and has no workers hired through Labor Contractors.

ABC Company is only required to submit a Payroll Employee Report on its 200 Payroll Employees.


Labor Contractor
Employee Report Only

Company B has 25 Payroll Employees and 100 workers hired through Labor Contractors — all in California.

Company B is required to submit a Labor Contractor Employee Report for its 100 Labor Contractor Employees, but not a Payroll Employee Report.


Both Report Types

Company C has 100 Payroll Employees and 125 workers hired through Labor Contractors — all in California.

Company C is required to submit both a Payroll Employee Report on its 100 Payroll Employees and a Labor Contractor Employee Report on its 125 Labor Contractor Employees.

Parent companies with subsidiaries

Affiliated companies may choose to submit a single pay data report or they may choose to submit separate pay data reports for each entity.

For the following two Pay Data Reporting examples, suppose a company, ABC Parent Company has two affiliated entities. All 3 entities are required to submit a pay data report, either combined or separately.

Within this group of affiliated entities, they have five establishments: ABC Parent Company Main Headquarters, Affiliated Entity A – Establishment 1, Affiliated Entity A – Establishment 2, Affiliated Entity B – Establishment 1, and Affiliated Entity B – Establishment 2.

Parent company and affiliates file a single pay data report

Employers that submit a combined report for multiple entities must provide information on each entity included in the report, which is a new requirement for filing year 2022. Important note: Employers should not provide information on entities that are not being reported on in the pay data report being filed.

Suppose ABC Parent Company, files a single Payroll Employee Report covering itself and two affiliated entities. The report should include details about each establishment (location) for all entities.

Assuming, for purposes of this Pay Data Reporting example, that all employees are in the same job category, pay band, race/ethnicity, and sex/gender, the pay data report would have the following rows:

  • ABC Parent Company
  • Affiliated Entity A – Establishment 1
  • Affiliated Entity A – Establishment 2
  • Affiliated Entity B – Establishment 1
  • Affiliated Entity B – Establishment 2

Each affiliated entity files a separate pay data report

If each entity files a separate pay data report, then the report should only include its own information.

Continuing the previous Pay Data Reporting example, if each entity is filing separately, then each report should only include information for the establishments of each entity.

The three separate reports would be as follows:

  • Pay Data Report #1
    • ABC Parent Company

  • Pay Data Report #2
    • Affiliated Entity A – Establishment 1
    • Affiliated Entity A – Establishment 2

  • Pay Data Report #3
    • Affiliated Entity B – Establishment 1
    • Affiliated Entity B – Establishment 2

Payroll Employee Pay Data Reporting Examples

CA PDR Payroll examples
California Pay Data Reporting Examples – Payroll Employees

Important Definitions

  • Employee – An individual on an employee’s payroll, and can include part-time employees. “Employee” may refer to a Payroll Employee, Labor Contractor Employee, or both.
  • Employer – A private individual or entity that is obligated to file a Pay Data Report on Payroll and/or Labor Contractor Employees.
  • Snapshot Period – A single pay period between October 1 and December 31 of the reporting year. It is only used to identify the Payroll Employees or Labor Contractor employees that should be included in the report.

Payroll Employee Snapshot Periods

This is a single pay period between October 1st and December 31st of the reporting year. Any individual that worked during this Snapshot Period should be included in the Payroll Employee Report.

Snapshot Period – Employer with multiple pay period types

In this Pay Data Reporting example, suppose an employer has 200 employees for all of October. Of these employees, 100 are paid bi-weekly while the other 100 are paid on the first of the month. Also, assume that the employer chooses October 15th – 29th for their Snapshot Period.

For the employer’s pay data report, they would report on all 200 employees, because they were all employed during the Snapshot period, even though half of them were not paid in the selected period.

Which employers are required to file Payroll Employee Reports?

A private employer that has 100 or more employees in the previous year and either are based in CA or have at least one employee in CA must submit a pay data report to the CRD covering the Payroll Employees.

An employer has the required amount of employees if they employed 100+ individuals during the Snapshot Period or regularly employed 100+ employees during the reporting year.

In the columns below, we outline three Pay Data Reporting examples that go over different types of scenarios when the employer is required to submit a Payroll Employee Report.


Seasonal
Employees

An employer is considered to have the required number of Payroll Employees if they either had 100+ employees in the snapshot period OR regularly had 100+ employees during the reporting year.

Suppose an employer typically has a three-month season during the calendar year and they regularly had 100+ Payroll Employees during that season.

The employer is required to submit a Payroll Employee Report.


Work Locations Inside
and Outside of CA

Payroll Employees located inside and outside of CA are counted when determining whether an employer has 100+ employees.

Suppose an employer has a total of 150 employees, half of whom work inside CA and the other half work outside CA.

The employer is required to submit a Payroll Employee Report as they had over 100 total Payroll Employees.


Part-Time Payroll
Employees

Part-time employees, including those that work partial days and fewer than each day of the work week, are counted the same as full-time employees.

Suppose an employer has 60 employees who work every day and 40 who work every other day, but no more than 80 work on any given day. The employer is considered to have 100 employees for reporting purposes.

The employer is required to submit a Payroll Employee Report.

Which employees should be included in a Payroll Employee Report?

Single establishment employer in California

Suppose an employer has a single establishment in Los Angeles, CA that has 200 employees working at the location during the chosen Snapshot Period. The employer should submit a Pay Data Report for all 200 employees, even if some of these employees were working remotely (in CA or otherwise).

Multiple establishment employer in California

In this Pay Data Reporting example, suppose an employer has 1,000 employees working across 4 establishments in CA. The employer’s Payroll Employee Report should cover all 1,000 employees.

If 50 of these employees were working remotely (whether in CA or not), the employer’s report should still cover these 50 employees.

Multiple establishment employer with establishments inside and outside of California

Suppose an employer has one establishment in CA that has 100 employees (with 10 remote workers in AZ) and one establishment in AZ with 50 employees (with 5 remote workers in CA) during the Snapshot Period. The employer would submit a Payroll Employee Report for:

  • Establishment-level data for the CA establishment and its 100 employees
  • Establishment-level data for the AZ establishment and only the 5 CA remote workers.

The employer should not submit data on the 45 employees that are assigned to the AZ establishment and work from AZ.

Establishment not based in California (remote workers)

In this Pay Data Reporting example, suppose an employer has a single establishment based in OR and it has 150 employees in the chosen Snapshot Period. Among these 150 employees, there is 1 employee that works remotely from CA.

The employer should submit a Payroll Employee Report for establishment-level data that only covers the one employee that works remotely from CA.


Labor Contractor Employee Pay Data Reporting Examples

CA PDR Contractor examples
California Pay Data Reporting Examples – Labor Contractor Employees

Important Definitions

  • Labor Contractor – An individual or entity that supplies a Client Employer with workers to perform labor within their usual course of business.
  • Labor Contractor Employee – An individual on a Labor Contractor’s payroll, including a part-time individual, for whom the Labor Contractor is required to withhold federal social security taxes from their wages and who performs labor for a Client Employer within their usual course of business.
  • Client Employer – A private individual or entity that has workers hired through Labor Contractors.
  • Snapshot Period – A single pay period between October 1 and December 31 of the reporting year. It is only used to identify the Payroll Employees or Labor Contractor Employees that should be included in the report.

Labor Contractor Employee Snapshot Periods

This is a single pay period between October 1st and December 31st of the reporting year.

A Client Employer should collaborate with each of its Labor Contractors to determine a snapshot period and gather information regarding their Labor Contractor Employees.

If a Client Employer has multiple Labor Contractors, then they can choose the same or different snapshot periods for each Labor Contractor. It is important to note that the CRD encourages the use of the same Snapshot Period across all Labor Contractors though it is not required.

Snapshot Period – Labor Contractors with multiple pay period types

In this Pay Data Reporting example, suppose a company has 100 Labor Contractor Employees from two different Labor Contractors for all of October. Labor Contractor A has a weekly pay period, while Labor Contractor B has a monthly pay period on the first of the month.

The Client Employer and both Labor Contractors decided together that October 15th – 29th would be the Snapshot Period.

For the Labor Contractor employee pay data report, they would report on all 100 Labor Contractor Employees, because they were all employed during the Snapshot period, even though half of them were not paid in the selected period.

Which employers are required to file Labor Contractor Employee Reports?

A private employer that has 100 or more Labor Contractor Employees in the previous year AND either are based in CA or have at least one Labor Contractor Employee based in CA must submit a pay data report to the CRD covering the Labor Contractor Employees.

When determining if a Client Employer is required to submit a Labor Contractor Employee Report:

  • They must count the total number of Labor Contractor Employees across all Labor Contractors.
  • If the Client Employer hires more than 100 Labor Contractor Employees then they are required to submit a report.
    • This applies even if they hired fewer than 100 from any one Labor Contractor.

In the columns below, we outline three Pay Data Reporting examples that go over different types of scenarios when the employer is required to submit a Labor Contractor Employee Report.


Seasonal Employers

An employer is considered to have the required number of Labor Contractor Employees if they either had 100+ Labor Contractor Employees in the snapshot period (across all Labor Contractors) OR regularly had 100+ Labor Contractor Employees during the reporting year.

Suppose an employer typically has a three-month season during the calendar year and they regularly had 100+ Labor Contractor employees during that season.

They are required to submit a Labor Contractor Employee Report.


Work Locations Inside
and Outside of CA

Both Labor Contractor Employees located inside and outside of CA are counted when determining whether an employer has 100+ Labor Contractor Employees.

Suppose an employer has a total of 150 workers hired through Labor Contractors, half of whom work inside CA and the other half work outside CA.

The employer would be required to submit a Labor Contractor Employee Report as they had over 100 total Labor Contractor Employees.


Part-Time Labor
Contractor Employees

Part-time Labor Contractor Employees, including those that work partial days and fewer than each day of the work week, are counted the same as full-time Labor Contractor Employees.

Suppose an employer hires 60 Labor Contractor Employees who work every day and 40 who work every other day, but no more than 80 work on any given day. The employer is considered to have 100 Labor Contractor Employees for reporting purposes.

The employer is thus required to submit a Labor Contractor Employee Report.

Which Labor Contractor Employees should be included in a Labor Contractor Employee Report?

Single establishment Client Employer in California

Suppose a Client Employer has a single establishment in San Francisco, CA that has 400 Labor Contractor Employees working at the location during the chosen Snapshot Period. The Client Employer should submit a Pay Data Report for all 400 Labor Contractor Employees, even if some of them were working remotely (in CA or otherwise).

Multiple establishment Client Employer in California

In this Pay Data Reporting example, suppose a Client Employer has 2,000 Labor Contractor Employees working across 6 establishments in CA. The Client Employer’s Labor Contractor Employee Report should cover all 2,000 Labor Contractor Employees.

If 25 of these Labor Contractor Employees were working remotely (whether in CA or not), the Client Employer’s report should still cover them.

Multiple establishment Client Employer with establishments inside and outside of California

Suppose a Client Employer has one establishment in CA that has 50 Labor Contractor Employees (with 10 remote workers in NV) and one establishment in OR with 100 Labor Contractor Employees (with 20 remote workers in CA) during the Snapshot Period. The Client Employer would submit a Labor Contractor Employee Report for:

  • Establishment-level data for the CA establishment and its 50 Labor Contractor Employees.
  • Establishment-level data for the OR establishment and only the 20 CA remote workers.

The Client Employer should not submit data on the 80 Labor Contractor Employees that are assigned to the OR establishment and work from OR.

Establishment not based in California (remote workers)

In this Pay Data Reporting example, suppose a Client Employer has a single establishment based in AZ and it has 100 employees in the chosen Snapshot Period. Among these 100 workers, there are 5 Labor Contractor Employees that work remotely from CA.

The Client Employer should submit a Labor Contractor Employee Report for establishment-level data that only covers the 5 Labor Contractor Employees that work remotely from CA.


California Pay Data Report Examples – Takeaway

Takeaway for Pay Data Reporting Examples

The new California Pay Data Reporting SB-1162 mandate requires that certain employers submit data regarding Payroll Employees and Labor Contractor Employees to the California Civil Rights Department annually.

By providing these California Pay Data Reporting examples, we’ve covered a lot of in-depth scenarios. Hopefully, this article has provided insight and a deeper understanding of the new reporting and its requirements.

Use this interactive questionnaire tool for California Pay Data Reporting Questionnaire to help determine if filing is required in under a minute.

BoomTax, The Boom Post, and its affiliates do not provide tax, legal or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. You should consult your own tax, legal and accounting advisors prior to engaging in any transaction.

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