California Civil Rights Department Sues Employers Over Pay Data Reporting
California's Civil Rights Department sued two employers for missing mandatory pay data reports under new law.
Why it matters: Employers with 100+ employees must comply with expanded pay data reporting under Senate Bill 1162 or risk legal penalties and litigation. General counsels should prioritize accurate reporting amid stronger state enforcement to avoid fines and reputational damage.
- On September 16, 2026, California's Civil Rights Department sued California Food Management, LLC and Coast 2 Coast Coaching for failing to file mandated workforce pay data reports.
- Senate Bill 1162, effective January 1, 2026, requires private employers with 100+ employees to report mean and median hourly wages plus expanded demographic pay data.
- Employers must now categorize employees into 23 job categories, up from 10, broadening reporting detail to enhance pay equity analysis.
- The reporting deadline for the 2025 data was May 13, 2026, requiring annual submissions to the Civil Rights Department.
On September 16, 2026, the California Civil Rights Department (CRD) sued two employers for failure to submit their statutorily required pay data reports. The CRD enforces California's pay data reporting law, part of broader pay equity efforts.
The CRD, formerly known as the Department of Fair Employment and Housing, requires private employers with 100 or more payroll employees—including private client employers with 100 or more labor contractor employees—to annually submit detailed pay, demographic, and workforce data. The deadline for the 2025 reporting year was May 13, 2026.
Senate Bill 1162, effective January 1, 2026, expanded reporting requirements to include mean and median hourly wage disclosures by demographic group, increasing transparency. It also mandated classification of employees into 23 job categories, a major increase from 10 previously. This expansion aims to provide deeper insight into wage disparities.
Kevin Kish, Director of the CRD, stated: "Every year, workers nationwide lose out on billions of dollars because of factors like their gender or race. We can't solve the problem by burying our heads in the sand." This underlines the department's commitment to enforcement and the risks employers face for non-compliance, including legal penalties.
The legal actions against California Food Management, LLC, a Burger King franchisee, and Coast 2 Coast Coaching, Inc., an after-school program provider, signal increased enforcement activity. Failure to comply can lead to lawsuits, fines, and increased scrutiny from regulators, heightening the legal risks for general counsels and HR professionals.
Employers must now ensure accurate, timely, and comprehensive pay data submissions to meet California's heightened pay equity standards. The CRD's public enforcement demonstrates that compliance is no longer optional but a mandated legal obligation under California law.
For more context, a Los Angeles Times report provides additional independent coverage of this enforcement action and its implications.
By the numbers:
- 2 employers sued — California Food Management, LLC and Coast 2 Coast Coaching
- 23 job categories — required employee classifications for 2026 reports, up from 10
- May 13, 2026 — deadline for 2025 year pay data reporting
Yes, but: While the expanded reporting requirements increase transparency, some employers may face challenges implementing 23 job categories accurately, potentially leading to unintentional reporting errors amid the new regime.
What's next: CRD enforcement actions are expected to increase in late 2026 and 2027 as employers submit reports under the new rules, with potential penalties for further noncompliance.