The first quarter of a California year is not a planning quarter. It is a delivery quarter, and this one is denser than most. Three dates fall inside it, one of them has already gone, and the work that follows each is unevenly distributed in a way the calendar does not advertise.
February 1: the notice that was due nine days ago
SB 294 required every California employer, with no size threshold, to give each current employee a standalone written notice on or before 1 February 2026. New hires receive it at hire. Everyone receives it annually thereafter.
The Labor Commissioner published a template, California Workplace – Know Your Rights, which sits with the required-posters material on the Department of Industrial Relations website in English and Spanish. Using it removes the drafting risk entirely, and there is no good reason to draft your own.
The mistake we are seeing most. The template lives on a page called Required Posters, so employers have printed it and put it on the break room wall. That does not discharge the obligation. The statute requires a standalone written notice given to each employee, in the manner you normally use for employment communications. A poster is not a notice to a person. Post it if you like, but send it as well.
If you missed the date, send it now and record the date you sent it. The obligation does not lapse because the deadline passed, and the gap between nine days late and never is the whole of the difference if anyone ever asks.
Two practical points on delivery. First, the notice must go out in the language you normally use for employment communications with that employee, so a Spanish-speaking workforce needs the Spanish version, not a note saying one is available. Second, retain proof of delivery for three years. An email to a distribution list, saved with its date, is adequate. A recollection is not.
March 30: the emergency contact designation
The same statute carries a second obligation with a later date and less attention. By 30 March 2026, you must give existing employees the opportunity to designate an emergency contact to be notified if the employee is arrested or detained at work or during work hours. From then on, you must offer the opportunity at hire. And you must honor the designation when the circumstance arises.
Note that this is not your ordinary emergency contact field. Most HRIS records carry a next-of-kin contact for a medical emergency. This is a distinct designation for a distinct event, and an employee may reasonably want a different person. Treat it as a new field with a new prompt, not as a re-use of one you already have.
The penalty structure is worth reading carefully, because the second tier is not like the first. General violations carry a penalty of up to $500 per employee for each violation. Violations of the emergency contact provisions carry a penalty of up to five hundred dollars per employee for each day the violation occurs, to a maximum of ten thousand dollars per employee. A daily, per-employee penalty is an unusual construction in California employment law, and it exists because the legislature expected it to be quietly ignored.
The payroll review January was supposed to do
The state minimum wage rose to $16.90 per hour on 1 January. The exempt salary floor for the executive, administrative and professional exemptions is two times that figure for full-time employment, which puts it at $70,304 a year.
Most employers handle the hourly increase automatically, because payroll systems are built to handle it. The exempt floor is where the error lives, and it is a particular kind of error: it does not announce itself, it accrues quietly, and it surfaces two years later as a misclassification claim with unpaid overtime, meal and rest premiums, waiting time penalties, and derivative wage statement claims attached.
Run the whole exempt population against $70,304, not only the people you think are near the line. And remember that salary is a threshold, not a test. An employee paid $90,000 who does not meet the duties test is misclassified at any salary, and January is a reasonable time to review the duties as well as the number.
Two further figures moved on 1 January for the narrower exemptions. The computer software professional exemption is now $58.85 per hour, $10,214.44 per month, or $122,573.13 per year. The licensed physician and surgeon exemption is now $107.17 per hour.
And check every local ordinance where you have someone working. A number of California cities set their own minimum wage above the state figure; several rose on 1 January, and the applicable rate follows where the work is performed rather than where your office is. Remote employees make this harder than it used to be, and nobody will tell you when one of them moves.
13 May: the pay data filing, which starts now
If you have 100 or more payroll employees, or 100 or more labor contractor employees, with at least one in California, the reporting year 2025 filing is due on 13 May 2026. The Civil Rights Department opened its portal on 2 February.
Two changes make this cycle different from the last.
First, penalties are no longer discretionary. Under SB 464, effective 1 January, a court must impose the civil penalty at the Department’s request rather than being permitted to. The amounts are unchanged: one hundred dollars per employee for an initial failure and two hundred for a subsequent one, but the word that changed is the word that mattered.
Second, you must now collect and store the demographic information you gather for the report separately from personnel records. That is a data architecture instruction, not a filing instruction, and you comply with it before you file rather than while you file. If you assembled your last report by exporting fields from the same system that holds performance reviews and disciplinary records, the assembly method itself is now the problem.
Reporting year 2025 also adds three fields to both reports: exemption status, employment type, and weeks worked in the reporting year. Weeks worked is the one that catches people, because most payroll systems don’t expose it in a form you can simply export. Decide now how you’ll derive it. Three months is comfortable. Three weeks is not.
The quiet one: personnel files
SB 513 took effect on 1 January and creates no deadline at all, which is exactly why it will be missed.
Where you maintain training records, they now belong in the personnel file, and each must include the employee’s name, the provider’s name, the duration and date, the core competencies covered (including equipment or software skills), and any resulting certification. Failure to produce a personnel file within thirty days of a request exposes you to a civil penalty, injunctive relief, and attorney’s fees.
There is no date by which you must do this. There is only the request, which arrives without warning, usually from a former employee, usually shortly before a claim. Thirty days is not long enough to reconstruct four years of training records from vendor emails. It is ample if the file was already right.
The first quarter in one table
| Date | What is owed | Who it applies to |
|---|---|---|
| January 1 | New wage floors in payroll; exempt population reviewed against $70,304 | All employers |
| January 1 | Pay data demographics separated from personnel records | 100 or more employees |
| January 1 | Training records brought into the personnel file in the required form | All employers that maintain them |
| February 2 | Know Your Rights notice to every current employee, proof retained three years | All employers |
| February 2 | Pay data portal open | 100 or more employees |
| March 30 | Emergency contact designation offered to every existing employee | All employers |
| May 13 | Reporting year 2025 pay data report filed | 100 or more employees |
Nothing on that list is difficult. Every item on it is a task with an owner, a date, and a piece of evidence. What sinks employers of twenty-five to five hundred is not the difficulty. It is that no single person has been told the list exists.
Sources
- California Department of Industrial Relations, required posters and the Know Your Rights template, dir.ca.gov.
- California Department of Industrial Relations, minimum wage, dir.ca.gov.
- California Civil Rights Department, pay data reporting and frequently asked questions, calcivilrights.ca.gov.
- Chaptered text of SB 294, SB 464 and SB 513, 2025 session; Labor Code section 1198.5.
This describes general California employment requirements. It is not legal advice about your organization, and it does not account for a collective bargaining agreement, an industry-specific order, or a local ordinance that may change the answer.