New California Pay Data Reporting Requirement Under SB 973

New California Pay Data Reporting Requirement Under SB 973

SB 973 requires that – on or before March 31, 2021, and on or before March 31 each year thereafter – private employers of 100 or more employees that also are required to file annual Employer Information Reports (EEO-1) pursuant to federal law must submit annual pay data reports to the Department of Fair Employment and Housing (“DFEH”) that contain specified wage information. The DFEH has issued FAQs on compliance with SB 973, which make clear that the DFEH will issue a sample form and instructions to help employers navigate this new reporting requirement. For more information on this new pay data reporting requirement, you may review EP's prior publication on this topic, which can be found here.

As between EP and its production company clients, it is the production companies as the EEO-1 employers that must file the pay data reports with the DFEH for their production workers.