Still Using EEO-1 Categories? California Is Moving On

California employers subject to the State’s Pay Data Reporting requirements should be aware of upcoming changes enacted through Senate Bill 464 (SB 464). The legislation modifies California’s existing pay data reporting requirements and is intended to expand workforce data reporting and improve consistency in how employers classify and report employee information. The changes become effective January 1, 2027. 

California Pay Data Reporting requirements apply to private employers with 100 or more employees nationwide that have employees who are assigned to a California establishment or who regularly perform work while physically located in California. The requirement applies regardless of where the employer’s headquarters are located.    

Employers typically report: 

• Employer information, including company details, industry classification, and reporting establishment information. 

  
  

• Employee demographic information, including race/ethnicity and sex categories. 

  
  

• Job classification information, currently based on EEO-1 job categories. Beginning with future reporting cycles under the updated requirements, employers will transition to reporting based on Standard Occupational Classification (SOC) Major Occupational Groups. 

  
  

• Compensation data, including annual W-2 wages and employee pay bands. 

  
  

• Hours worked during the reporting year. 

Employers use a designated payroll period during the fourth quarter of the reporting year (October 1 through December 31, 2026) to determine the employees included in the report, compensation data and hours worked. 

• For 2027, the anticipated filing deadline will be May 12, 2027.  

  
  

• California Pay Data Reports are submitted annually by the second Wednesday in May. 

  
  

• California Pay Data Reports cover employee data from the prior calendar year (2026).  

  
  

• Under SB 464, covered employers will transition from reporting employees using the traditional 10 EEO-1 job categories to expanded occupational classifications based on Standard Occupational Classification (SOC) major occupational groups.  

  
  

• At this time, California has not issued a formal EEO-1-to-SOC Major Occupational Group crosswalk that employers can simply use for the 2027 Pay Data Reporting transition.  

  
  

• The California Civil Rights Department (CRD) is expected to provide additional instructions, FAQs, or technical guidance before the first filing under the new requirements.  

  
  

• The current EEO-1 categories are broad groupings (for example, "Professionals" or "First/Mid-Level Officials and Managers"), while SOC Major Groups classify work based on occupation type (for example, Computer and Mathematical Occupations or Architecture and Engineering Occupations).  

  
  

• SOC categories are based on the federal SOC system used by agencies such as the Bureau of Labor Statistics.   

The official source for SOC Major Occupational Groups is the U.S. Bureau of Labor Statistics (BLS) Standard Occupational Classification (SOC) website

The updated requirements reflect California’s continued focus on pay transparency, workforce data collection, and identifying potential pay disparities. Employers should expect increased attention on how positions are classified, how compensation information is maintained, and how demographic information is collected and reported. 

How C2 Essentials Can Help 

C2 Essentials will confirm whether your organization is subject to California Pay Data Reporting requirements. 

C2 Essentials already maintain workforce demographic, job classification, and compensation data for federal compliance obligations, including EEO reporting, VETS-4212 reporting, and other contractor recordkeeping requirements. C2 Essentials will assist covered clients with preparing a Workforce Data Review evaluating employee classifications, job titles, and workforce data to support accurate reporting. 

Aligning HRIS, payroll, and workforce reporting processes now can help contractors reduce administrative burdens, improve data accuracy, and maintain consistency across federal and state compliance requirements.