California’s Expanded Pay Data Categories: Now Is the Time to Start SOC Mapping

Wednesday, October 7, 2026

Takeaways

• California’s May 2027 pay data reports will shift from the current 10 EEO-1 categories to 23 job categories based on the federal Standard Occupational Classification system.
• To prepare for the May 2027 filing, employers should use the final quarter of the year to map existing roles to the new categories, address classification challenges, confirm system capabilities and coordinate with labor contractors.
• Beginning 01.01.27, the maximum penalty for repeat failures to file increases to $1,000 per employee.

Related links

• California SB 1237
• California SB 464

Article

Employers subject to California’s pay data reporting requirements should use the remainder of 2026 to prepare for significant changes to the 2027 reporting cycle.

The May 2027 filing will be the first California pay data report to require employees to be grouped into 23 job categories based on the federal Standard Occupational Classification (SOC) system instead of the 10 EEO-1 categories employers have used for years.

This filing will also be the first cycle subject to the significantly higher penalties for repeat filing failures under Senate Bill (SB) 1237. Employers that begin preparing now will have time to complete the work before the filing period.

SB 464, signed in October 2025, replaces the 10 EEO-1 job categories with 23 job categories based on the federal SOC system, beginning with reports covering calendar year 2026 data, which are due in May 2027.

Rather than broad EEO-1 categories such as “Professionals” or “Laborers and Helpers,” employers must classify employees by occupational function, using categories such as “Computer and Mathematical Occupations,” “Healthcare Practitioners and Technical Occupations,” and “Building and Grounds Cleaning and Maintenance Occupations.”

Because there is little alignment between the EEO-1 and SOC categories, employers will likely need to reassign nearly all positions to new categories to ensure accurate classification. This will require review of job duties, titles, and organizational structure. The change applies to both payroll employee reports and labor contractor employee reports.

• Hybrid roles. Many positions combine duties that fall into more than one category. SOC coding guidance generally directs that a worker performing activities in multiple occupations be classified in the occupation requiring the highest level of skill or, if skill levels are similar, the one in which the worker spends the most time.
   
• Supervisors and managers. Under the SOC system, many first-line supervisors may fall within the same occupational group as the workers they supervise, while managers likely fall in Management Occupations. Classification depends on job duties and the applicable SOC guidance. Thus, employers whose EEO-1 reporting grouped all supervisors as “First/Mid-Level Officials and Managers” may see significant shifts.
   
• Generic or legacy titles. Titles such as “Associate,” “Specialist,” “Analyst,” or “Coordinator” often cover different work across departments. These titles typically need to be broken out by department or function before they can be SOC mapped.

Because the May 2027 report will apply the new categories to calendar year 2026 data, employers will need to classify 2026’s workforce under the new system. The advantages of completing the mapping before year end include:

• Avoid first-quarter pressure. Year-end close, W-2 processing, and data validation already occupy the first quarter.
   
• Time to address issues. Mapping may reveal inconsistent job titles, outdated job descriptions, or system fields that cannot accommodate the new categories. These are easier to correct before the reporting year closes.
   
• Opportunity to test. Applying the new categories to the current workforce allows employers to review the results before filing.

SB 1237 raises the maximum penalty for repeat failures to file from $200 to $1,000 per employee, effective Jan. 1, 2027. The maximum penalty for a first-time failure remains $100 per employee. Combined with SB 464, which made court-imposed penalties mandatory upon request by the California Civil Rights Department (CRD), the cost of missing a filing is higher than ever.

1. Inventory California job titles. Determine whether any titles already have SOC codes (for example, from immigration filings or other state reporting) and identify gaps. 
    
2. Map existing roles to the 23 SOC categories. Apply the classification principles discussed above, and flag hybrid, supervisory, and generic-title roles for closer review.
    
3. Confirm system capabilities. Verify that HRIS and payroll systems can store SOC assignments by job title for future reporting. 
    
4. Align with other reporting. Consider how the reassignments affect EEO-1 and other reporting obligations. 
    
5. Consider a privileged pay equity analysis. The new categories will give CRD a more detailed view of the workforce. Employers may wish to work with counsel on a privileged compensation analysis before submitting their data. 
    
6. Coordinate with labor contractors. Labor contractors must supply the pay data needed for the labor contractor employee report. Confirm early that they understand the new categories, because a failure to file now carries mandatory penalties.

Reports are due the second Wednesday of May (May 12 for 2027). The May 2027 filing, covering 2026 data, is the first under both the SOC categories and SB 1237’s higher penalties for repeat failures. Employers that complete SOC mapping this quarter will be better prepared for the filing period.