Compliance Stuff

With pay data reports due to the California Civil Rights Department (CRD) on May 13, 2026, California employers must ensure they are prepared to meet their reporting obligations. As previously discussed  here , employers with 100 or more employees are required to file a pay data report with the CRD. Client employers with 100 or more labor contractor employees are also required to submit a report. The CRD’s  website  contains additional information regarding the reporting requirements, including frequently asked questions and a handbook on data reporting. Employer Reporting Requirements Employers must submit reports based on the snapshot period. The snapshot period is a single pay period between October 1 and December 31 of the reporting year. The employer selects the snapshot period. Employees on the employer’s payroll during the snapshot period must be included in the report, though much of the reported data must reflect the entire reporting year. Employers must capture ...

Key Takeaways Illinois recently concluded its legislative session, with many employment-related bills being sent to Governor JB Pritzker for possible enactment into law. As of this publication, the governor has already enacted two laws that amend Illinois Equal Pay Act and Prevailing Wage Act requirements. Additional bills that may be signed into law include changes to the Illinois Human Rights Act, the Illinois Workplace Transparency Act, nursing breaks, and new categories of leaves of absence, among others. Employers with Illinois workers should be aware of several proposed new employment laws and amendments to existing laws that may be enacted if signed by the Governor later this year. Below are summaries of the proposed new laws, as well as bills the Governor has already signed into law. Paid Breaks for Nursing Mothers in the Workplace Effective: January 1, 2026 |  SB 212 SB 212 proposes changes to the Nursing Mothers in the Workplace Act, joining New York in requiring employer...

I was recently asked whether public companies are required, as a technical matter, to have principal accounting officers (PAOs). While PAOs are not strictly required, companies without PAOs should be aware of the result—that the controller will fill that role by default and be considered a Section 16 officer . Certain SEC filings like Form S-3 and Form 10-K require the signature of the company’s PAO or controller. T he PAO is a designation that is often held by a company’s controller or chief financial officer (CFO). Sometimes the PAO designation is held by someone who is not the controller or CFO. But is a PAO technically required? Rule 16a-1 of the Exchange Act is instructive and defines an officer as the “principal accounting officer ( or, if there is no such accounting officer, the controller )” (emphasis added) . Under Rule 16a-1, if a company does not have a PAO, then the controller is deemed to fill that role and is considered a Section 16 officer. It’s possible for the controll...