Existing law provides for unemployment compensation benefits for eligible individuals in the state who are unemployed through no fault of their own. Existing law requires an employer, as defined, to make contributions for unemployment insurance premiums and to file specified reports with the Director of Employment Development, including, among other reports, a report of contributions, a quarterly return, and a report of wages paid, as specified.

This bill would require the Employment Development Department to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes. The bill would require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on behalf of one or more employers with 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.

This bill would require the department, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, and to enable access to relevant wage data, as specified. The bill would require the department to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits. The bill would also require or authorize the department to work with other specified state agencies relating to reporting requirements on workforce and employment.

This bill would require the department to use existing federal and state grant funds to the extent available and to implement the bills provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits, as described above, on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

Under existing law, the information obtained in the administration of the Unemployment Insurance Code is for the exclusive use and information of the Director of Employment Development in the discharge of their duties and is not open to the public. However, existing law requires the director to permit the use of the information for specified purposes, including to enable governmental agencies to verify or determine eligibility for public social services. Existing law provides that a person who knowingly accesses, uses, or discloses this confidential information without authorization is guilty of a misdemeanor.

This bill would also require the director, on or before January 1, 2028, to enable the State Department of Social Services and the State Department of Health Care Services to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, as prescribed. The bill would further require the director, on or before January 1, 2028, to enable the Office of the California Education Interagency Council to access any relevant wage data necessary for the purposes of supporting the councils agendas, reports, work products, and resources. councils specified purposes. By expanding the scope of a crime, this bill would impose a state-mandated local program.

Existing constitutional provisions require that a statute that limits the right of access to the meetings of public bodies or the writings of public officials and agencies be adopted with findings demonstrating the interest protected by the limitation and the need for protecting that interest.

This bill would make legislative findings to that effect.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law provides for unemployment compensation benefits for eligible individuals in the state who are unemployed through no fault of their own. Existing law requires an employer, as defined, to make contributions for unemployment insurance premiums and to file specified reports with the Director of Employment Development, including, among other reports, a report of contributions, a quarterly return, and a report of wages paid, as specified.

This bill would require the Employment Development Department to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes. The bill would require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, on behalf of one or more employers with 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.

This bill would require the department, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, and to enable access to relevant wage data, as specified. The bill would require the department to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits. The bill would also require or authorize the department to work with other specified state agencies relating to reporting requirements on workforce and employment.

This bill would require the department to use existing federal and state grant funds to the extent available and to implement the bills provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits, as described above, on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

Under existing law, the information obtained in the administration of the Unemployment Insurance Code is for the exclusive use and information of the Director of Employment Development in the discharge of their duties and is not open to the public. However, existing law requires the director to permit the use of the information for specified purposes, including to enable governmental agencies to verify or determine eligibility for public social services. Existing law provides that a person who knowingly accesses, uses, or discloses this confidential information without authorization is guilty of a misdemeanor.

This bill would also require the director, on or before January 1, 2028, to enable the State Department of Social Services and the State Department of Health Care Services to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, as prescribed. The bill would further require the director, on or before January 1, 2028, to enable the Office of the California Education Interagency Council to access any relevant wage data necessary for the purposes of supporting the councils agendas, reports, work products, and resources. By expanding the scope of a crime, this bill would impose a state-mandated local program.

Existing constitutional provisions require that a statute that limits the right of access to the meetings of public bodies or the writings of public officials and agencies be adopted with findings demonstrating the interest protected by the limitation and the need for protecting that interest.

This bill would make legislative findings to that effect.

The California Constitution requires the state to reimburse local agencies and school districts for certain costs mandated by the state. Statutory provisions establish procedures for making that reimbursement.

This bill would provide that no reimbursement is required by this act for a specified reason.

Existing law provides for unemployment compensation benefits for eligible individuals in the state who are unemployed through no fault of their own. Existing law requires an employer, as defined, to make contributions for unemployment insurance premiums and to file specified reports with the Director of Employment Development, including, among other reports, a report of contributions, a quarterly return, and a report of wages paid, as specified.

This bill would require the Employment Development Department to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes. The bill would require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.

This bill would require the department, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, and to enable access to relevant wage data, as specified. The bill would require the department, in adopting and developing the procedures, to consult with specified state departments and interest holders, and would require the department to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits. The bill would also require or authorize the department to work with other specified state agencies relating to reporting requirements on workforce and employment.

This bill would require the department to use existing federal and state grant funds to the extent available and to implement the bills provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits, as described above, on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

Existing law provides for unemployment compensation benefits for eligible individuals in the state who are unemployed through no fault of their own. Existing law requires an employer, as defined, to make contributions for unemployment insurance premiums and to file specified reports with the Director of Employment Development, including, among other reports, a report of contributions, a quarterly return, and a report of wages paid, as specified.

This bill would require the Employment Development Department to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes. The bill would require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.

This bill would require the department, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, as specified. The bill would require the department, in adopting and developing the procedures, to consult with specified state departments and interest holders, and would require the department to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits. The bill would also require or authorize the department to work with other specified state agencies relating to reporting requirements on workforce and employment.

This bill would require the department to use existing federal and state grant funds to the extent available and to implement the bills provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits, as described above, on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

Existing law provides for unemployment compensation benefits for eligible individuals in the state who are unemployed through no fault of their own. Existing law requires an employer, as defined, to make contributions for unemployment insurance premiums and to file specified reports with the Director of Employment Development, including, among other reports, a report of contributions, a quarterly return, and a report of wages paid, as specified.

This bill would require the Employment Development Department to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes. The bill would require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.

This bill would require the department, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, as specified. The bill would require the department, in adopting and developing the procedures, to consult with specified state departments and interest holders, and would require the department to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits. The bill would also require or authorize the department to work with other specified state agencies relating to reporting requirements on workforce and employment.

This bill would require the department to use existing federal and state grant funds to the extent available and to implement the bills provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits, as described above, on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

Date of Hearing: August 5, 2026

ASSEMBLY COMMITTEE ON APPROPRIATIONS

Buffy Wicks, Chair

SBPCA Bill Id:SB 1054

Author:(Cabaldon) – As Amended Ver:June 18, 2026

Urgency: No State Mandated Local Program: Yes Reimbursable: No

SUMMARY:

This bill requires certain employers to report additional information to the Employment Development Department (EDD) and requires EDD to share the information with certain state agencies to facilitate benefits administration and other program purposes.

Specifically, this bill:

1. Requires, beginning July 1, 2027, an employer with 10 or more employees to include information regarding each employee’s total monthly wage, industry, occupation, worker type, and hours worked in the employer’s report of wages to EDD; requires the report to be filed electronically at least monthly unless the employer qualifies for a waiver; and requires EDD to minimize employer reporting burdens to the extent feasible by aligning and streamlining requirements for the report and deploying user-friendly programming interfaces.
2. Requires EDD, by July 1, 2027, to adopt and develop procedures for sharing certain types of employment and wage information with the Department of Social Services (DSS), Department of Healthcare Services (DHCS), and Office of the California Education Interagency Council (Council) for certain purposes.
3. Requires EDD to work with the California Statewide Automated Welfare System (CalSAWS) on necessary systems changes to implement such data sharing.
4. Requires EDD to enable DSS and DHCS to access hours worked and other necessary employment data to support employment-related verifications for an employee’s initial eligibility for and ongoing receipt of public benefits, including CalFresh and Medi-Cal, and requires EDD to consult with DSS, DHCS, and stakeholders (which must include the Office of Cradle-to-Career Data (C2C), County Welfare Directors Association of California, and CalSAWS) on implementation.
5. Requires EDD to work with the Council related to the collection of relevant wage data necessary for the Council’s statutory purpose and requires EDD to enable the Council to access such wage data.
6. Requires EDD to enable data sharing access for DSS, DHCS, and the Council by January 1, 2028, or when EDD notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
7. Requires EDD to work with the California Workforce Development Board (CWDB) and Labor and Workforce Development Agency (LWDA) to implement certain workforce program reporting requirements related to job training services and requires EDD to provide CWDB and LWDA with relevant necessary wage data pursuant to EDD’s existing authority to share related information.
8. Authorizes EDD to work with C2C to support existing state data systems, dashboards, and reports related to the collection of employment data pursuant to EDD’s existing authority to share related information.
9. Requires EDD to use existing federal and state grant funds, to the extent available, to implement these provisions.

FISCAL EFFECT:

1. EDD estimates one-time costs of approximately $92 million to implement this bill, including making information technology system upgrades to enable additional employer data collection and developing new information sharing procedures with various state agencies in consultation with certain stakeholders (General Fund). EDD notes that the July 1, 2027, effective date in this bill is operationally infeasible and instead estimates a multi-year implementation timeline. Upon implementation, EDD estimates ongoing costs of approximately $52 million to maintain systems and procedures and work with employers to ensure compliance (General Fund). The author and sponsors of this bill cite the results of a fiscal impact report prepared by individuals from the University of San Francisco and Estuaire Advising, which estimates much lower costs of approximately $10 million one-time and $4 million ongoing to EDD to implement this bill. Although EDD’s estimate may represent the higher end of the range of costs, actual one-time and ongoing costs will likely be in the high tens of millions of dollars.
2. One-time automation costs ranging from approximately $250,000 to over $500,000 to DSS to update CalSAWS to implement data sharing provisions (General Fund) and approximately $292,000 to DHCS for DHCS’s share of system changes (25% General Fund, 75% federal funds). DSS estimates needing 12 months after publication of the final policy to either update existing interfaces with an Income and Eligibility Verification System or create a new interface to receive daily data updates from EDD. The automation would also enable batch processing of data for ongoing online publication.
3. Costs of approximately $450,000 in the first year and $435,000 annually thereafter to DSS for two additional staff positions to build and maintain a data pipeline between DSS and EDD (75% General Fund, 25% federal funds). Additionally, one-time costs of approximately $100,000 to DSS for data ingestion, cloud computing, and data storage needed to build the pipeline (75% General Fund, 25% federal funds).

Regardless of this bill, recent changes to federal law require DSS to gather additional information to verify a recipient’s CalFresh eligibility and payments. DSS estimates the costs of contracts with private entities to obtain such data at approximately $2 million annually (50% General Fund, 50% federal funds) for one vendor and over $16 million in the first year with year-over-year cost increases of approximately 15% for another vendor (30% General Fund, 70% federal funds). By requiring EDD to provide employment verification data to DSS, this bill negates the need for DSS to enter into contracts for such data, resulting in future ongoing cost savings to DSS commensurate to the cost of the contracts.

1. One-time costs of approximately $6,000 to DHCS to make necessary changes to BenefitsCal, the online benefits management portal (75% General Fund, 25% federal funds).

Similar to DSS, future ongoing cost savings of an unknown amount to DHCS to the extent this bill negates the need for DHCS to enter into contracts for Medi-Cal employment verification data (General Fund and federal funds).

1. Absorbable costs to the Council to work with EDD to access and utilize wage data to further Council purposes (General Fund).
2. Costs of approximately $46,000 in the first year and $92,000 annually thereafter to CWDB to work with EDD to access and utilize wage data for workforce programs (General Fund).
3. Costs of approximately $373,000 annually to C2C to work with EDD and accommodate more frequent data sharing (General Fund).

COMMENTS:

1. Purpose. According to the author:

The current wage file collected by EDD only includes quarterly earnings and employer ID numbers. As H.R. 1 threatens to reduce Californians’ benefit access, the need to collect employees’ hours worked is critical to ensure that California residents do not lose access to their Medicaid and SNAP benefits…

Additionally, California will soon require more precise data on labor market outcomes to administer the new Workforce Pell program and enable the [CEIC] to conduct analyses that support planning efforts to better algin education pathways with workforce outcomes in sectors critical to California’s economy. A lack of data on employees’ occupation will inhibit these efforts.

1. Background. EDD Base Wage File. As part of EDD’s administration of the state’s unemployment insurance, disability insurance, and paid family leave programs, as well as EDD’s collection of the employer and employee payroll taxes that fund such programs, EDD maintains a data source known as the “base wage file,” which includes an employee’s first and last name, social security number, total subject wages, wage plan code, total Personal Income Tax (PIT) wages, and total PIT withheld. Each employer reports base wage file data to EDD’s Tax Branch on a quarterly basis, which EDD stores securely to protect confidentiality and may share with specified state agencies for certain authorized purposes only. In total, approximately 1.6 million employers report 22.5 million wage lines per quarter on behalf of approximately 18.5 million California wage earners.

Workforce Programs. SB 755 (Roth), Chapter 815, Statutes of 2022, required EDD and CWDB to collaborate on a plan to measure, analyze, and report on employment and earnings outcomes for individuals who received job training services through federal and state programs. One of the SB 755 report recommendations is for the state to expand base wage file data collection to include the hours worked by an employee, thus allowing calculation of the hourly wage from quarterly employee earnings, as well as the employee’s region and occupation. The report concludes that without such information, it is difficult to assess variation in earnings across employees (such as whether low earnings is driven by low wages, low hours worked, or both), whether earnings are considered a living wage in the region, and whether job training program participants are placed in a “training-related job.”

Public Benefits Programs. H.R. 1 made federal funding for state Medicaid expansion pursuant to the Affordable Care Act and for the Supplemental Nutrition Assistance Program (Medi-Cal and CalFresh in California, respectively) contingent on work or community engagement requirements for program applicants. Under H.R. 1, an applicant must participate in a qualifying activity for up to 20 hours per week, or 80 hours averaged monthly, and such eligibility must be determined every six months, instead of every year.

Scope of This Bill. This bill increases the amount of information that an employer with more than 10 employees must report to EDD as part of the base wage file to include an employee’s total monthly wage, industry, occupation, worker type (for example, salaried or hourly), and hours worked. This bill also requires an employer to electronically submit the data to EDD monthly. Thus, this bill expands the base wage file to include most of the information recommended by the SB 755 report, except for an employee’s region, and the type of information, such as hours worked, needed by DSS and DHCS to facilitate verification of an employee’s initial and ongoing eligibility for Medi-Cal and CalFresh benefits. This bill requires EDD to enable the sharing of such data with DSS, DHCS, and CWDB for these described purposes, as well as with the Council and C2C for additional workforce development purposes.

As noted in the Assembly Labor Committee’s analysis of this bill, excluding smaller employers from this bill may “create confusion or conflict with the existing system, as the information that the EDD would be receiving from employers with 10 or more employees would be different and at a different frequency than that of employers with fewer than 10 employees.” The analysis also notes that this bill does not include explicit authorization for EDD to share information with another state entity to help implement the Workforce Pell Grant program.

1. Support and Opposition. This bill is co-sponsored by California Competes, California EDGE Coalition, and UNITE-LA, which argue this bill “is a practical step with far-reaching impacts on economic mobility, college affordability, and access to public benefits” and that “many states have already begun collecting these data elements, demonstrating that California can seamlessly implement similar system enhancements.” This bill is also supported by various other education, social service, and workforce development groups.

This bill is opposed by the City of La Verne, which argues, “this approach places a substantial and ongoing administrative burden on employers to solve a state-level data deficiency… an overreach that shifts responsibility away from the State and onto employers without sufficient safeguards or funding.”

Analysis Prepared by: Irene Ho / APPR. / (916) 319-2081

Date of Hearing: June 24, 2026

ASSEMBLY COMMITTEE ON LABOR AND EMPLOYMENT

Liz Ortega, Chair

SBPCA Bill Id:SB 1054

Author:(Cabaldon) – As Amended Ver:June 18, 2026

SENATE VOTE: 38-0

SUBJECT: Unemployment insurance: reporting requirements

SUMMARY: Requires, beginning July 1, 2027, specified employers and other entities to include in their report of wages, information about total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified; requires this information to be submitted on a monthly basis; and requires the EDD to share this information with various state entities for specified objectives. Specifically, this bill:

1. Requires the EDD to work with employers to enhance the reporting of employment and earning data by employers, consistent with federal law and regulations.
2. Requires the EDD, where feasible, to minimize employer reporting burdens by aligning and streamlining definitions and requirements for the report of wages, deploying user-friendly application programming interfaces, and implementing other means to simplify reporting processes.
3. Requires, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on behalf of one or more employers with 10 or more employees, to include in their report of wages information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in a format approved by the EDD.
4. Requires the information reported to be filed electronically at least monthly, as specified.
5. Requires the EDD, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data, as specified.
6. Requires the EDD to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked.
7. Requires the EDD to work with the Office of the California Education Interagency Council related to the collection of employment data, as specified, to support the council’s purposes (see (11) below in existing law).
8. Requires the EDD to work with the California Workforce Development Board (CWDB) and the Labor and Workforce Development Agency (LWDA) to implement workforce program reporting requirements, as specified. (See (6) below in existing law.)
9. Authorizes the EDD to work with the Office of Cradle-to-Career Data to support existing state data systems, dashboards, and reports related to the collection of employment data, as specified.
10. Requires the EDD to use existing federal and state grant funds to the extent available.
11. Requires the EDD to implement the above provisions on or before July 1, 2027, except that the EDD must begin the data sharing process to verify hours worked on January 1, 2028, or when the EDD notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
12. Permits the use of any information in the EDD Director’s possession, on or before January 1, 2028, for the following purposes:
    1. To enable the State Department of Social Services (DSS) and the Department of Health Care Services (DHCS) to access, to the extent permitted by federal laws and regulations, hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.
       1. Requires the EDD, in implementing (a) to consult with the DSS, the DHCS, and stakeholders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and CalSAWS.
    2. To enable the Office of the California Education Interagency Council to access, to the extent permitted by federal laws and regulations, any relevant wage data necessary to support the council’s purposes (see (11) below in existing law).
13. Defines the following terms:
14. “Hours worked” to mean the total hours worked by each worker each month. The employer may report 40 hours worked for each week any duties were performed by a full-time employee and shall report hours paid or a reasonable estimate of the hours worked for each week duties were performed by a part-time employee.
15. “Occupation” to mean an occupation listed in the United States Bureau of Labor Statistics’ Standard Occupational Classification system or the job title of each worker.
16. “Worker type” to mean the salaried or hourly, and full-time, part-time, intern, or apprentice status of each worker.
17. Provides that the bill is known as Better Data, Better Coverage, Better California Act.
18. States the intent of the Legislature to require the EDD to collect hours worked and occupational classification as part of employer wage reporting, in a manner that minimizes employer burden, improves data quality, and maximizes cross-program value for California’s education, workforce, and safety net systems.
19. Makes findings and declarations.

EXISTING LAW:

1. Establishes the EDD within the LWDA and tasks it with, among other duties, the administration of the Unemployment Insurance (UI) and Disability Insurance (DI) programs. Unemployment Insurance Code § 301.
2. Establishes the UI program as a joint state/federal program, administered by the EDD that provides weekly UI payments for workers who lose their job through no fault of their own. Eligibility for benefits requires that the claimant be able to work, available for work, be seeking work, and be willing to accept a suitable job. Unemployment Insurance Code §§ 100-144, 301-456.
3. Requires, among other things, an employer to electronically file a report of contributions, a quarterly return, and a report of wages paid to the employer’s workers, as specified. Unemployment Insurance Code § 1088.
4. Requires, in addition to information reported pursuant to (3) above, an employer to submit information on new employees, and among other things, a report containing the following:
   1. The name, address, and social security number of the employees.
   2. The employer’s name, address, state employer identification number (if one has been issued), and identifying number assigned to the employer under Section 61095 of the Internal Revenue Code of 1986.
   3. The first date the employee worked. Unemployment Insurance Code § 1088.5.
5. Requires the EDD Director to permit the use of any information, such as wage and employment data, in the director’s possession to the extent necessary for specified purposes and under specified conditions. Unemployment Insurance Code § 1095.
6. Requires that the state’s workforce system operate in a manner that is data driven and evidence based when setting priorities, investing resources, and adopting practices. Unemployment Insurance Code §14000(b)(3).
7. Requires that the state’s workforce system be outcome oriented and accountable, by measuring results for program participants, including outcomes related to program completion, employment, and earnings. Unemployment Insurance Code § 14000(b)(5).
8. Establishes the CWDB as the body responsible for assisting the Governor in the development, oversight, and continuous improvement of the workforce system. Unemployment Insurance Code § 14010.
9. Requires the CWDB to develop a workforce metrics dashboard that measures the state’s human capital investments in workforce development to understand the impact of these investments on the labor market. The workforce metrics dashboard is required to do the following:
   1. Provide a status report on credential attainment, training completion, degree attainment, and participant earnings from workforce education and training programs.
   2. Provide demographic breakdowns, including, to the extent possible, race, ethnicity, age, gender, veteran status, wage and credential or degree outcomes, and information on workforce outcomes in different industry sectors.
   3. Measure the performance of the following workforce programs: community college career technical education, the Employment Training Panel, Title I and Title II of the federal Workforce Investment Act of 1998 (Public Law 105-220), Title I and Title II of the federal Workforce Innovation and Opportunity Act (WIOA) of 2014 (Public Law 113-128), Trade Adjustment Assistance, and state apprenticeship programs.
   4. Measure participant earnings in California, and to the extent feasible, in other states. Unemployment Insurance Code § 14013(i).
10. Requires the EDD and the CWDB to work collaboratively to measure and report on training-related job placement outcomes for individuals receiving job training services provided through the workforce system. Unemployment Insurance Code § 14017.1.
11.  Establishes the Office of the California Education Interagency Council within the Government Operations Agency for the purpose of accomplishing the following goals:
    1. Proactively evaluating and addressing the changing nature of work and the economy, and supporting the advancement of state educational attainment, equity, and workforce goals.
    2. Integrating and aligning efforts across elementary and secondary education, postsecondary education, employers, and the statewide workforce system, and maximizing the impact of federal and state funding investments to ensure effective student pathways to quality work and well-paying careers and to contribute to economic growth.
    3. Increasing collaboration across postsecondary education and the workforce development systems statewide, and with employers to ensure flexibility and support for meeting the skill-building and upskilling needs of adults.
    4. Working in regions throughout the state to ensure that education supply and statewide workforce demand are aligned.
    5. Being a forum for communication to discuss the impacts of proposed intersegmental and cross-sector issues, including, but not limited to, changes to elementary, secondary, and postsecondary education graduation requirements, including California State University and University of California admissions changes. Government Code § 11900 et seq.
12.  Establishes the California Cradle-to-Career Data System to be a source for actionable data and research on education, economic, and health outcomes for individuals, families, and communities, and provide for expanded access to tools and services that support the navigation of the education-to-employment pipeline. Establishes the Office of Cradle-to-Career Data within the Government Operations Agency as the managing entity for the Cradle-to-Career Data System. Education Code § 10860 et seq.

FISCAL EFFECT: According to the Senate Appropriations Committee:

• The bill’s administrative costs to the Employment Development Department (EDD) have yet to be identified but would likely reach the low tens of millions of dollars minimally (See Staff Comments regarding funding source).
• The Department of Social Services (DSS) indicates that it would incur one-time costs of up to $600,000, and ongoing costs of $435,000 to implement the provisions of the bill. (General Fund).
• The Office of Cradle to Career Data (C2) indicates that it would incur ongoing costs of $373,000 to collaborate with EDD and accommodate the bill’s increased data frequency (General Fund).
• Costs to the Department of Health Care Services (DHCS) and the Education Interagency Council (EIC) have yet to be determined, but combined would likely, at a minimum, reach the hundreds of thousands of dollars (General Fund).

Staff comments regarding funding source: As noted above, the bill would require EDD to perform its workload using federal and state grant funds to the extent available. The General Fund would be likely be required to make up any shortfall.

COMMENTS:

EDD quarterly wage reporting and the base wage file:

Employers of all sizes are required to file with the EDD a quarterly report with information about total wages paid, taxes withheld, and employer contributions for the quarter. According to the EDD, approximately 1.6 million employers report 22.5 million wage lines per quarter on behalf of approximately 18.5 million California wage earners.

This information becomes part of what is known as the “base wage file,” which the EDD maintains and uses in its administration of the UI, DI, and Paid Family Leave (PFL) benefit programs, as well as for tax administration and regulatory compliance. The base wage file includes employee first and last name, social security number, total subject wages, wage plan code, total personal income tax (PIT) wages, and total PIT withheld of each employee in California, recorded separately for each employer on a quarterly basis. Base wage file data is stored securely by the EDD to protect confidentiality, and the EDD shares the data only with specified state agencies and for specific allowable purposes through Unemployment Insurance Code Section 1095.

This bill would authorize the EDD Director to share this information with additional entities and for additional purposes (see above for the bill provisions).

SB 755 (Roth, Chapter 815, Statutes of 2022) Report^[1]:

The base wage file is also a key source of data used to evaluate performance outcomes of state and federal workforce programs, as it contains employment and earnings data before and after enrollment in workforce programs.

In 2022, SB 755 (Roth) was signed into law, requiring the EDD and the CWDB to collaborate to create a plan for measuring, analyzing, and reporting on employment and earnings outcomes for individuals who received job training services through specific programs, including the WIOA Title 1 managed by the EDD and all programs managed by the CWDB.

One of the recommendations in the report is for the state to expand base wage file data collection to include hours worked, region, and occupation. This additional information was recommended because employers currently only report quarterly employee earnings. Without information about hours worked, it is difficult to determine an hourly wage to understand how earnings vary. Furthermore, without geographical information, it is not possible to determine if the wages are considered a living wage in the region. Additionally, it is not feasible to determine if job training program participants are placed in a ‘training-related job’ because there is no data related to occupation in the base wage file.

SB 1054 aims to implement some of those recommendations by requiring employers to additionally include in their quarterly report to the EDD information on total monthly wage and hours worked, industry, occupation, and worker type (salaried or hourly, and full-time, part-time, intern, or apprentice, status) for each employee.

Committee Comments:

As written, this bill requires the new information to be included in the existing quarterly report of wages, but also to be submitted electronically on a monthly basis. These timelines seem to be in conflict with each other, unless the intent is to have the entire quarterly wage information now be reported on a monthly basis. If so, this would require amending Unemployment Insurance Code Section 1088 to specify that employers must submit the required information on a monthly basis rather than quarterly.

Furthermore, the additional information required to be submitted pursuant to this bill is only required for employers with 10 or more employees, whereas the existing quarterly report is required for all employers. This could also create confusion or conflict with the existing system, as the information that the EDD would be receiving from employers with 10 or more employees would be different and at a different frequency than that of employers with fewer than 10 employees.

Lastly, as noted above, the SB 755 report recommended the base wage file additionally collecting from employers regional information about employees. Given that the bill would implement the other two pieces of information recommended (hours worked and occupational information), the author may wish to consider including the recommended regional information.

According to the author: “The current wage file collected by EDD only includes quarterly earnings and employer ID numbers. As H.R. 1 threatens to reduce Californians’ benefit access, the need to collect employees' hours worked is critical to ensure that California residents do not lose access to their Medicaid and SNAP benefits. As of now, the State relies on a shared-services access contract with Equifax where they provide employment and income data to the Department of General Services at an exorbitant cost to verify eligibility.

Additionally, California will soon require more precise data on labor market outcomes to administer the new Workforce Pell program and enable the California Education Interagency Council to conduct analyses that support planning efforts to better align education pathways with workforce outcomes in sectors critical to California’s economy. A lack of data on employee’s occupation will inhibit these efforts.”

Committee Comment: The author argues that SB 1054 would also help position California for successful Workforce Pell implementation. However, as noted above, there must be explicit authorization in statute for the EDD to share information in the base wage file with another state entity. As written, this bill does not include such authorization for the Workforce Pell Grant program.

Arguments in Support

California Competes, CA EDGE Coalition, and UNITE-LA, co-sponsors of this measure, write that “The bill’s proposed data collection will improve coordination and planning across existing investments in education and training, support access to federal grant aid for students enrolled in short-term programs, and help minimize benefit loss stemming from administrative burden due to new federal work requirements. SB 1054 strengthens California’s ability to evaluate whether skills training and education programs lead to successful employment outcomes. Current data collection captures quarterly earnings and employer identifiers, but not the hours worked or job type metrics that are essential for understanding job quality or the occupation metric needed to assess program-to-employment results. This limits the state’s ability to plan strategically for workforce needs and align education investments with good jobs.”

Arguments in Opposition

The City of La Verne writes that “this approach places a substantial and ongoing administrative burden on employers to solve a state-level data deficiency. Employers would be required to implement new tracking systems, report more frequently, and provide detailed employee-level data, all while the State expands data sharing across multiple agencies and programs. This represents an overreach that shifts responsibility away from the State and onto employers without sufficient safeguards or funding. Additionally, the bill dramatically expands the collection and distribution of sensitive employment data, increasing the risk of data misuse, security vulnerabilities, and unintended consequences for workers. While intended to streamline eligibility verification, the scale of data collection and interagency access raises serious concerns about privacy and long-term data management.”

Prior and Related Legislation

AB 1098 (Fong), Chapter 446, Statutes of 2025, established the California Education Interagency Council within the Government Operations Agency to align education and workforce systems, support adult skill development, and address the changing nature of work and the economy.

SB 638 (Padilla), Chapter 457, Statutes of 2025, revised the California Career Technical Education Incentive Grant (CTEIG) Program and required the Department of Education to consult with the California Education Interagency Council when developing and awarding CTEIG grants, ensuring that program standards and priorities are informed by a cross-sector perspective. SB 638 also charged the Council with advisory responsibilities related to career technical education, career pathways, and workforce development.

SB 755 (Roth), Chapter 815, Statutes of 2022, required the EDD to work with the CWDB to measure and report specified information regarding aggregate labor market outcomes of individuals receiving training services through the workforce system. This bill required, among other things, that the board and department create a plan to use existing data to match relevant employee occupational data, employee place of employment data, and employee hours worked data, to persons who enroll in job training services, and to outline various objectives. Required the board and department, upon appropriation by the Legislature, to implement the plan, and within 2 years of the appropriation, to summarize and provide an initial report of their findings to specified committees of the Legislature.

SB 753 (Roth), Chapter 550, Statutes of 2021, required, among other things, the EDD Director to permit the use of specified wage data with the CWDB in order to assist the board in its obligation to evaluate program outcomes for the grant programs it administers.

AB 1245 (Cooley), Chapter 222, Statutes of 2016, required employers with 10 or more employees to file all reports and returns, and remit all contributions for unemployment insurance premiums to the EDD electronically, as specified. Extended the application of these electronic filing requirements to all employers beginning on January 1, 2018.

AB 2148 (Mullin), Chapter 385, Statutes of 2014, required the California Workforce Investment Board (now known as the CWDB) to assist the Governor in the development of an annual workforce metrics dashboard to measure investment in workforce development, as specified.

REGISTERED SUPPORT / OPPOSITION:

Support

California Competes: Higher Education for a Strong Economy (Co-Sponsor)
California Edge Coalition (Co-Sponsor)
UNITE-LA (Co-Sponsor)
Bay Area Council
California In-Home Supportive Services Consumer Alliance
CEO Leadership Alliance Orange County
National Talent Collaborative
Orange County United Way
University of California Student Association
Yolo County Commission on Aging and Adult Services
Yolo County In-Home Supportive Services Advisory Committee

Opposition

City of LA Verne

Other

Los Angeles Chamber of Commerce

Analysis Prepared by: Erin Hickey / L. & E. / (916) 319-2091

1. https://edd.ca.gov/siteassets/files/about_edd/sb-755-report---expanding-workforce-performance-analysis-and-employer-quarterly-wage-reports.pdf ↑

Date of Hearing: June 17, 2026

ASSEMBLY COMMITTEE ON INSURANCE

Lisa Calderon, Chair

SBPCA Bill Id:SB 1054

Author:(Cabaldon) – As Amended Ver:June 8, 2026

SENATE VOTE: 38-0

SUBJECT: Unemployment insurance: reporting requirements

SUMMARY: Expands the breadth and frequency of required employment and earning data reporting to Employment Development Department (EDD), and requires EDD to share relevant employment data with the Department of Social Services (DSS), the Department of Health Care Services (DHCS), and the Office of the California Education Interagency Council (OCEIC). Specifically, this bill:

1. Requires EDD to work with employers to enhance the reporting of employment and earning data by employers required under existing law, and, where feasible, to align and streamline definitions and requirements for the report of wages, deploy user-friendly application program interfaces, and otherwise streamline reporting processes.
2. Beginning July 1, 2027, requires every employer with 10 or more employees, and every individual or organization that, as an agent, reports wages on behalf of one or more employers with 10 or more employees, to include information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in the report of wages required under existing law; and requires the report to be filed electronically at least monthly, unless the employer receives a waiver as specified..
3. On or before January 1, 2028, requires EDD to permit the use of any information in their possession to the extent necessary for the following purposes:

• To enable DSS and DHCS to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.
• To enable the OCEIC to access any relevant wage data necessary for the purposes of supporting the California Education Interagency Council’s [“Council’s”] agendas, reports, work products, and resources.

1. Requires EDD to adopt and develop procedures for the sharing of hours worked and other necessary employment data pursuant to 3), above.
2. Requires EDD to use existing federal and state grant funds to the extent available, and to implement the provisions of the bill on or before July 1, 2027, except with respect to data sharing pursuant to 3), above, which is required to commence on January 1, 2028, or when EDD notifies the Legislature the CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
3. Requires EDD to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process pursuant to 3), above.
4. Requires EDD to work with the OCEIC related to the collection of employment data pursuant to 3), above, for the purposes of supporting the council’s agendas, reports, work products, and resources; and requires EDD to work with the California Workforce Development Board (CWDB) and the Labor and Workforce Development Agency (LWDA) to implement existing workforce program reporting requirements and to provide any relevant necessary wage data, including as collected pursuant to 2), above.
5. Requires EDD to consult with DSS, DHCS, and stakeholders, including, but not limited to the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and CalSAWS, with respect to 3) above.
6. Requires EDD to work with the Office of Cradle-to-Career Data to support existing state data systems, dashboards, and reports related to the collection of employment data pursuant to existing law.
7. Defines “hours worked” to mean the total hours worked by each worker each month; specifies that the employer may report 40 hours worked for each week any duties were performed by a full-time employee, and to report hours paid or a reasonable estimate of the hours worked for each week duties were performed by a part-time employee.
8. Defines “occupation” to mean an occupation listed in the United States Bureau of Labor Statistics’ Standard Occupational Classification system or the job title of each worker.
9. Defines “worker type” to mean the salaried or hourly, and full-time, part-time, intern, or apprentice status of each worker.
10. Makes several findings and declarations pertaining to the need for high-quality labor market data to evaluate and improve workforce development and educational programs, and to facilitate verification of eligibility for public benefits.

EXISTING LAW:

1. Establishes EDD in the LWDA, and vests it with various duties and responsibilities including the administration of the Unemployment Insurance (UI) program, the State Disability Insurance (SDI) program, and the Paid Family Leave (PFL) program. (Unemployment Insurance (UI) Code Secs. 301, et seq.)
2. Establishes the UI program as a joint state/federal program, administered by EDD, that provides weekly payments for workers who lose their job through no fault of their own. (UI Code Secs. 100, et seq., and 301, et seq.)
3. Requires each employer to file a report with EDD of employer contributions to the UI fund and worker contributions to the Disability Fund, a quarterly return, and a report of wages paid to the employer’s workers in the form and containing any information prescribed by the director of EDD; requires that the report be filed electronically; and authorizes employers to request a waiver from electronic filing requirements, as specified. (UI Code Sec. 1088)
4. Requires each employer to file a report with EDD reporting the hiring of any employee to whom the employer anticipates paying wages, and the hiring of any employee who previously worked for the employer but had been separated from that prior employment for at least 60 consecutive days; and specifies that the report shall include the name, address, and social security number of the employees, the employer’s name, address, state employer identification number, and identifying number assigned to the employer under Section 61095 of the Internal Revenue Code, and the first date the employee worked for the employer. (UI Code Sec. 1088.5)
5. Establishes that, except as otherwise specifically provided in the UI Code, information obtained in the administration of the UI Code is confidential, not open to the public, and for the exclusive use and information of the director of EDD in discharge of their duties. (UI Code Sec. 1094(a))
6. Specifies that information released to authorized entities pursuant to other provisions of the UI Code shall not be admissible in evidence in any action or special proceeding, other than one arising out of the provisions of the UI Code or as specified. (UI Code Sec. 1094(b))
7. Provides that the information obtained in the administration of the UI Code may be tabulated and published in statistical form for use by federal, state, and local governmental departments and agencies, and the public, except that the name of the employing unit or of any worker shall never be divulged in the course of the tabulation or publication. (UI Code Sec. 1094(c))
8. Provides that any person who knowingly accesses, uses, or discloses any confidential information without authorization is guilty of a misdemeanor. (UI Code Sec. 1094(f))
9. Authorizes EDD to share wage and employment data, under specified conditions, for a variety of purposes, including the evaluation of workforce and education programs, and the administration of public benefit programs, as respectively specified. (UI Code Sec. 1095)
10. Pursuant to federal regulations, specifies that in order to receive federal grant funds intended for conducting a state UI program, the methods of administration of the program must include provision for maintaining the confidentiality of any information which reveals the name or any identifying particular about any individual or any past or present employer or employing unit, or which could foreseeably be combined with other publicly available information to reveal any such particulars, and must include provision for barring the disclosure of any such information, except as provided. (20 Code of Federal Regulations (CFR) §603.4)
11. Pursuant to federal regulations, specifies circumstances under which disclosure of confidential UI program information is permissible, provided it is authorized by state law and does not interfere with the efficient administration of the state UI program. (20 CFR §603.5)
12. Authorizes disclosure of confidential UI program information to a public official for use in the performance of their official duties; defines “performance of official duties” to mean administration or enforcement of law or the execution of the official responsibilities of a Federal, State, or local elected official; specifies that administration of law includes research related to the law administered by the public official; and further specifies that “performance of official duties” includes use of confidential UI program information for education or workforce training program performance accountability and reporting under Federal or State law. (20 CFR §603.5(e))

FISCAL EFFECT: Unknown.

COMMENTS:

1. Purpose. According to the author:

The current wage file collected by EDD only includes quarterly earnings and employer ID numbers. As H.R. 1 threatens to reduce Californians’ benefit access, the need to collect employees’ hours worked is critical to ensure that California residents do not lose access to their Medicaid and SNAP benefits. As of now, the State relies on a shared-services access contract with Equifax where they provide employment and income data to the Department of General Services at an exorbitant cost to verify eligibility.

Additionally, California will soon require more precise data on labor market outcomes to administer the new Workforce Pell program and enable the California Education Interagency Council to conduct analyses that support planning efforts to better align education pathways with workforce outcomes in sectors critical to California’s economy. A lack of data on employees’ occupation will inhibit these efforts.

This bill is co-sponsored by California Competes, California EDGE Coalition, and UNITE-LA, non-profit organizations focused on education and workforce development.

1. EDD and the base wage file. EDD is responsible for administering the state’s unemployment insurance (UI), disability insurance, and paid family leave programs, among others, including collecting the employer and employee payroll taxes that underlie them. In addition to providing funds necessary to administer the programs, these transactions serve as a rich source of administrative data relating to employment in California. This data source is known as the “base wage file.”

As a 2024 report from EDD, CWDB, and LWDA, discussed in detail in Comment #3, explains:

As part of the UI, DI, and PFL benefit program administration, the EDD is responsible for gathering and maintaining information in the base wage file, which assists in determining benefit program eligibility, distributing benefits, and minimizing fraud in the distribution of benefits. In California, the base wage file includes employee first and last name, social security number, total subject wages, wage plan code, total PIT wages, and total PIT withheld of each employee in California recorded separately for each employer on a quarterly basis. Base wage file data is reported from employers to EDD’s Tax Branch on a quarterly basis and stored securely by EDD to protect confidentiality. In California, there are approximately 1.6 million employers reporting 22.5 million wage lines per quarter on behalf of approximately 18.5 million California wage earners.

For employers with more than 10 employees, and for entities reporting payroll for such employers, this bill would expand the information that must be reported to EDD for the base wage file to include total monthly wage, industry, occupation, worker type (i.e. salaried or hourly, and full-time, part-time, intern, or apprentice), and hours worked. For these employers, the bill would also increase the frequency of reporting from quarterly to monthly.

Given the value of this dataset for understanding the landscape of the state workforce, several states have already expanded the reporting requirements for the base wage file, consistent with the requirements of this bill. According to the coalition of education and workforce development non-profits who sponsor the bill, “18 states already collect data on work hours or pay rate, or are in the process of developing this reporting, and 15 states currently collect or will be collecting data on employee occupation.”

1. SB 755 report. In 2022, the Legislature passed SB 755 (Roth, Ch. 815, Stats. 2022), which required the CWDB and EDD to work collaboratively to measure and report on training-related job placement outcomes for individuals receiving job training services provided through the workforce system. SB 755 also required CWDB and EDD to work collaboratively to create a plan to use the existing unemployment insurance tax data collection infrastructure used to secure quarterly wage data from employers (i.e. the base wage file), to match relevant employee occupational data, employee place of employment data, and employee hours worked data, to persons who enroll in job training services, and to report this plan to the Legislature by January 1, 2024. This report, entitled “SB 755 (2022): Expanding Workforce Performance Analysis and Employer Quarterly Wage Reports,” was timely produced and reported to the Legislature. As part of the required plan, the report identified specific limitations on the scope of workforce training outcome evaluation due to the available data, as follows:

Many discussions at federal and state levels have identified the limitations within existing base wage files if the data is to be used for program evaluation and research. For example, only ‘quarterly earnings’ are available on employees. Without understanding hours paid and total compensation to arrive at an hourly wage, it can be challenging to understand variation in earnings across employees. When earnings are particularly low, it is not clear if this is driven by low wages, low hours worked, or both. […] In addition, it is not possible to determine if job training participants are placed in a ‘training-related job’ when there is no data related to occupation in the base wage file and limited information regarding the training services delivered in the participant data system. These limitations affect the type of performance analysis and evaluation, as well as broader research, that is feasible when relying on the base wage file […].

The sponsors of this bill raise similar points, arguing:

Current data collection captures quarterly earnings and employer identifiers, but not the hours worked or job type metrics that are essential for understanding job quality or the occupation metric needed to assess program-to-employment results. This limits the state’s ability to plan strategically for workforce needs and align education investments with good jobs. Additionally, current data limitations hinder institutions’ ability to assess how effectively program offerings meet workforce needs and support graduates in achieving their career goals. These limitations also constrain efforts to refine programs based on such evaluations.

By collecting data on hours worked and occupation, California will be better positioned to measure job placement and wage progression, evaluate workforce outcomes and trends, and better align training investments with high-quality job outcomes. This effort builds on the state’s interest in more meaningful measurement of workforce outcomes and supports statewide alignment initiatives, including the Cradle-to-Career Data System and the California Education Interagency Council.

That said, the report also recommended that policymakers wishing to expand the base wage file “consider costs and benefits of additional data elements.” Specifically, the report explains:

[P]olicymakers seeking to expand the base wage file may wish to consider three points. First, the collection of new data elements must not affect wage reporting codes or the benefit charge rating process or any other existing data element in the existing base wage system that could affect the timely processing of claims. Second, all employers, both public and private, will incur costs to upgrade their payroll systems to report any data enhancements. Future proposals must attempt to balance costs for both EDD and employers to enhance existing systems while maximizing benefits for improved performance analysis, evaluation, and research to drive learning and accountability. Third, changes to the base wage file result in significant IT project costs for EDD.

Consistent with the second consideration, the City of La Verne argues in opposition to the bill:

SB 1054 is intended to address gaps in the state’s existing wage data system by requiring employer to report additional information such as hours worked and occupation, largely to support workforce program evaluation and to comply with new federal work verification requirements tied to Medi-Cal and CalFresh eligibility.

However, this approach places a substantial and ongoing administrative burden on employers to solve a state-level data deficiency. Employers would be required to implement new tracking systems, report more frequently, and provide detailed employee level data, all while the State expands data sharing across multiple agencies and programs. This represents an overreach that shifts responsibility away from the State and onto employers without sufficient safeguards or funding.

Still, such enhancements and system updates may ultimately be necessary in order to meet new federal accountability requirements for critical grant funding. As the bill’s sponsors explain:

SB 1054 would also help position California for successful Workforce Pell implementation. The U.S. Department of Education’s regulations call on states to build out their administrative data collection by 2029 to track program participants’ outcomes into an occupation. Critically, to maintain Pell-eligibility, short-term programs will need to see at least 70 percent of their students employed in an occupation “for which the program prepares students” or “a comparable high-skill, high-wage, or in-demand occupation.” California currently does not collect this data as needed. However, SB 1054 will make this information available for the state.

1. H.R. 1 and eligibility verification demands. On July 4, 2025, President Trump signed into law H.R. 1, also known as the “One Big Beautiful Bill Act.” H.R. 1 was a budget bill, and included provisions spanning a wide variety of policy areas. Relevant to this bill, the federal funding for state Medicaid expansion pursuant to the Affordable Care Act (ACA) and for the Supplemental Nutrition Assistance Program (SNAP) was made contingent on compliance with specified eligibility and verification requirements. In California, these programs are known as Medi-Cal and CalFresh, respectively.

Specifically, H.R. 1 requires California to impose work or community engagement requirements for Medi-Cal and CalFresh applicants in order to qualify for federal funds. To meet the mandatory eligibility requirements, applicants for these programs must participate in a qualifying activity for up to 20 hours per week, or 80 hours averaged monthly. Qualifying activities include paid employment, volunteer work or community service, job training or work programs, education, workfare, or any combination of these activities. In addition, H.R. 1 requires eligibility to be determined every six months, rather than every year.

Economic Security CA Action, a non-profit dedicated to reducing income inequality, explains in support of this bill:

H.R. 1 imposes two major new compliance burdens on California’s benefits administration. First new work requirements for both Medicaid expansion enrollees and CalFresh recipients require 80 hours per month of qualifying work or other activities – verified at initial eligibility determination and at every subsequent renewal. Second, beginning January 1, 2027, H.R. 1 requires eligibility redeterminations to occur no less than every six months for the ACA expansion population – doubling California’s current renewal frequency and creating a corresponding surge in verification events that must be processed accurately and efficiently. Together, these provisions will require counties to verify compliance for an estimated 4.6 million ACA expansion enrollees at twice the current rate.

Without reliable, timely wage data in state systems, counties will be forced to rely on paper documentation submitted by enrollees themselves. California’s Department of Health Care Services has already warned that the new federal mandates will increase administrative workload and heighten the rate of procedural discontinuances. SB 1054 directly addresses this risk by making employer-reported data available for automated eligibility checks, enabling counties to verify compliance without burdening working families with duplicative documentation.

In response to the burdens imposed by H.R. 1, this bill seeks to streamline eligibility verification for Medi-Cal and CalFresh, among other public benefit programs, by requiring EDD to allow access to relevant employment data by DSS and DHCS, including hours worked information, which the bill also requires EDD to collect.

1. Confidentiality of base wage file. Both state and federal law impose strict confidentiality requirements on the use and disclosure of the base wage file. Section 1094(a) of the UI Code provides that, except as otherwise specifically provided in the UI Code, information in the administration of the UI Code is “confidential, not open to the public, and shall be for the exclusive use and information of the director in the discharge of [their] duties.” Violation of this confidentiality is a crime punishable as a misdemeanor.

Similarly, Part 603 of Title 20 of the Code of Federal Regulations details confidentiality and permissible disclosure of state unemployment compensation (UC) program information. 20 CFR §603.2 defines UC information to mean “information in the records of a State or State UC agency that pertains to the administration of the State UC law.” The same section specifies that this includes state wage reports collected under the Income and Eligibility Verification System (IEVS), that are obtained by the state UC agency for determining UC monetary eligibility.

§603.4 lays out the basic confidentiality requirement, specifying that in order to receive federal grant funds intended for conducting a state UC program, the methods of administration of the state UC program “must include provision for maintaining the confidentiality of any UC information which reveals the name or any identifying particular about any individual or any past or present employer or employing unit, or which could foreseeably be combined with other publicly available information to reveal any such particulars, and must include provision for barring the disclosure of any such information, except as provided [].” In other words, violation of the confidentiality requirements prescribed by federal law with respect to the base wage file can result in withholding of federal UI funding, which can have catastrophic consequences for the state UI program.

§603.5 lays out the exceptions to the confidentiality requirement, specifying that “[d]isclosure of confidential UC information is permissible under the exceptions [] only if authorized by State law and if such disclosure does not interfere with the efficient administration of the State UC law.” Relevant to this bill, §603.5(e) authorizes “disclosure of confidential UC information to a public official for use in the performance of [their] official duties”. The regulation defines “performance of official duties” to mean “administration or enforcement of law or the execution of the official responsibilities of a Federal, State, or local elected official” and specifies that administration of law includes “research related to the law administered by the public official.” It also specifies that “performance of official duties” includes use of confidential UC information for “education or workforce training program performance accountability and reporting under Federal or State law.”

Pursuant to the §603.5 requirement that any disclosure of confidential UI information must be authorized by state law, Section 1095 of the UI Code details a wide range of purposes for which the director of EDD shall permit the use of any information in the director’s possession to the extent necessary. This bill would add two provisions to that section, requiring EDD to provide access to information for the following purposes:

(as) To enable DSS and DHCS to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.

(at) To enable the OCEIC to access any relevant wage data necessary for the purposes of supporting the council’s agendas, reports, work products, and resources.

These purposes do not appear to conflict with the conditions under which federal regulations authorize confidential UI information disclosure. Both disclosures are made to “public officials” within the meaning of the federal regulations, and the former would be considered in furtherance of the administration or execution of the official duties of DSS and/or DHCS, with respect to the Medi-Cal and CalFresh programs, among others, that they are tasked with administering. Section 11902 of the Government Code, which details the Council’s purposes, places the mandate of the Council squarely in the realm of education and workforce training program performance accountability and reporting. It is therefore unlikely that the UI information disclosure required by this bill would violate federal confidentiality requirements for UI information, provided the disclosure is properly administered.

1. Potentially redundant authorities. Under existing law, Section 1095 already provides for information sharing purposes that are similar to, and potentially redundant with, the authority this bill would provide pursuant to subdivision (as), concerning public benefits programs.

Subdivision (f) of existing law requires EDD to provide access to information for purposes related to public benefits, as follows:

To enable federal, state, or local governmental departments or agencies, subject to federal law, to verify or determine the eligibility or entitlement of an applicant for, or a recipient of, public social services pursuant to Division 9 [citation] of the Welfare and Institutions Code, [the federal Social Security Act], and state or federal subsidies offered through the California Health Benefit Exchange [citation], when the verification or determination is directly connected with, and limited to, the administration of public social services.

Public benefits pursuant to Division 9 of the Welfare and Institutions Code include CalFresh, which is specifically enumerated in the new provisions, as well as nearly all other public benefits programs administered by DSS and DHCS.

Subdivision (ad) of existing law also specifically requires EDD to provide access to information for verifying Medi-Cal eligibility, as follows:

To enable [DHCS], the California Health Benefit Exchange, the Managed Risk Medical Insurance Board, and county departments and agencies to obtain information regarding employee wages, California employer names and account numbers, employer reports of wages and number of employees, and disability insurance and unemployment insurance claim information, for the purpose of […] verifying or determining the eligibility of an applicant for, or a recipient of, state health subsidy programs, limited to the Medi-Cal program [citation], and the Medi-Cal Access Program [citation], when the verification or determination is directly connected with, and limited to, the administration of the state health subsidy programs referenced in this [provision].

Accordingly, it is not clear whether the data access authority provided by subdivision (as) of this bill is entirely redundant with existing authorities pursuant to subdivisions (f) and (ad) of existing law. That said, this redundancy is unlikely to cause material practical or legal issues, since either way, the named entities would have the authority to access the information as needed for these purposes.

1. Committee Amendments.

Committee amendment #1: Explicitly ensuring compliance with federal law.

Though the purposes for which UI information would be disclosed under the bill seem consistent with federal regulations (see Comment #5), several other provisions of Section 1095 include explicit clarification that any sharing must comply with federal law and regulations (see, e.g., subdivisions (t), (y), (z), (ae), (af), (aq): “to the extent permitted by federal law and regulations”; (ab), (ac), (ak): “to the extent permitted by federal statutes and regulations”; (ad)(2): “subject to the requirements of, and provided to the extent permitted by, federal law and regulations, including Part 603 of Title 220 of the Code of Federal Regulations”; (ah): “to the extent not prohibited by federal law”; (ai): “subject to federal law, including the confidentiality, disclosure, and other requirements set forth in Part 603 of Title 20 of the Code of Federal Regulations”; (an): “to the extent permitted by state and federal laws and regulations”; (ap): “to the extent permissible by federal laws and regulations”).

While it seems unlikely that the new provisions added to Section 1095 would be construed to require sharing that is otherwise prohibited by federal law or regulations, the presence of explicit limitations in so many other provisions of the same section (various as they may be) warrants clarification. Considering misinterpretation, and consequent violation of federal law or regulation, could result in withholding of federal UI funds, the stakes are high enough that clarification seems worthwhile.

Accordingly, the author has agreed to the following amendments:

On page 21, in line 25, strike out “access” and insert: access, to the extent permitted by federal laws and regulations,

On page 21, in line 37, strike out “access” and insert: access, to the extent permitted by federal laws and regulations,

Committee amendment #2: Clarifying the purpose of disclosures to OCEIC.

The bill in print requires EDD to enable OCEIC to access “any relevant wage data necessary for the purposes of supporting the council’s agendas, reports, work products, and resources.” [Emphasis added.] While the purposes of the Council are specified by law and are consistent with permissible disclosures under the federal confidentiality regulations, it is not clear that access to wage data pursuant to the bill is limited to only what is necessary to fulfill the purposes the Council is explicitly intended to satisfy.

To clarify this limitation, the author has agreed to the following amendments:

On page 7, in lines 31 and 32, strike out “purposes of supporting the council’s agendas, reports, work products, and resources.” and insert: council’s purposes specified in Chapter 12.5 (commencing with Section 11900) of Part 1 of Division 3 of Title 22 of the Government Code.

On page 21, in line 38, strike out “purposes of supporting the council’s”, strike out line 39 and insert: council’s purposes specified in Chapter 12.5 (commencing with Section 11900) of Part 1 of Division 3 of Title 2 of the Government Code.

Committee amendment #3: Technical correction.

Section 1088.3(f) of the bill in print provides that “The department shall work with the Office of the California Education Interagency Council related to the collection of employment data pursuant to subdivisions (as) and (at) of Section 1095 […].” However, subdivision (as) does not provide any authorities pertinent to the OCEIC, and is therefore irrelevant to this provision.

To correct this technical error, the author has agreed to the following amendment:

On page 7, in line 30, strike out “subdivisions (as) and” and insert: subdivision

Committee amendment #4: Technical clarification.

Section 1095(as)(2) provides that “The department shall consult with the State Department of Social Services, the State Department of Health Care Services, and stakeholders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and the California Statewide Automated Welfare System (CalSAWS).” Though the paragraph is within the subdivision requiring EDD to enable DSS and DHCS to access employment data to support employment-related eligibility verifications for public benefits, it does not specify the purpose of the required consultation.

To clarify this requirement, the author has agreed to the following amendment:

On page 21, in line 30, strike out “The” and insert: In implementing this subdivision, the

1. Double referral. This bill is double-referred to the Assembly Committee on Labor & Employment.

REGISTERED SUPPORT / OPPOSITION:

Support

All Home
Bay Area Council
Building Skills Partnership
California Competes: Higher Education for a Strong Economy
California Edge Coalition
California In-home Supportive Services Consumer Alliance
California State Association of Counties (CSAC)
Ceo Leadership Alliance Orange County
Child Care Resource Center
Coalition of California Welfare Rights Organizations
Food Bank of Contra Costa and Solano
Jobtrain
Jvs Bay Area
Jvs Socal
National Talent Collaborative
Orange County United Way
The Institute for College Access & Success
Unite-la
University of California Student Association
Western Center on Law & Poverty, INC.
Yolo County Commission on Aging and Adult Services
Yolo County In-home Supportive Services Advisory Committee

Opposition

City of LA Verne

Analysis Prepared by: Landon Klein / INS. / (916) 319-2086

 THIRD READING  

Bill No: SB 1054

Author: Cabaldon (D), et al.

Amended: 3/26/26

Vote: 21

SENATE LABOR, PUB. EMP. & RET. COMMITTEE: 5-0, 3/25/26

AYES: Smallwood-Cuevas, Strickland, Cortese, Durazo, Laird

SENATE APPROPRIATIONS COMMITTEE: 7-0, 5/14/26

AYES: Cervantes, Seyarto, Cabaldon, Dahle, Grayson, Richardson, Wahab

SUBJECT: Unemployment insurance: reporting requirements

SOURCE: California Competes: Higher Education for a Strong Economy

California Edge Coalition

UNITE-LA

DIGEST:

This bill (1) requires specified employers and other affected entities to include information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified, in the report of wages filed with the Employment Development Department (EDD), (2) requires EDD to, among other things, permit the use of specified information to enable the State Department of Social Services (DSS) and the State Department of Health Care Services (DHCS) to access hours worked and specified employment data to support employment-related verifications for eligibility for public benefits, as specified, (3) requires EDD to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked, as specified, (4) requires or authorizes EDD to work with other specified state agencies relating to workforce and employment reporting requirements, as specified, and (5) requires EDD to begin the data sharing process to verify hours worked for public benefits on January 1, 2028, or when EDD notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

ANALYSIS:

Existing law:

1. Establishes the EDD within the LWDA. EDD is responsible for, among other duties, the administration of the Unemployment Insurance (UI) and Disability Insurance (DI) programs. (Unemployment Insurance Code §301)
2. Establishes the UI program as a joint state/federal program, administered by EDD that provides weekly unemployment insurance payments for workers who lose their job through no fault of their own. Eligibility for benefits requires that the claimant be able to work, available for work, be seeking work, and be willing to accept a suitable job. (Unemployment Insurance Code §§100-144, 301-456)
3. Requires, among other things, an employer to file a report of contributions, a quarterly return, and a report of wages paid to the employer’s worker, as specified. (Unemployment Insurance Code §1088)
   1. Requires all employers to file the report of contributions, quarterly return, and report of wage electronically. (Unemployment Insurance Code §1088 (h)(2))
   2. Authorizes employers to request a waiver from the electronic filing requirements, as specified. (Unemployment Insurance Code §1088(h)(3))
4. Requires, in addition to information reported with Unemployment Insurance Code Section 1088, an employer to submit information on new employees, and among other things, a report containing the following:
   1. The name, address, and social security number of the employees.
   2. The employer’s name, address, state employer identification number (if one has been issued), and identifying number assigned to the employer under Section 61095 of the Internal Revenue Code of 1986.
   3. The first date the employee worked. (Unemployment Insurance Code §1088.5)
5. Requires the EDD Director to permit the use of any information, such as wage and employment data, in the director’s possession to the extent necessary for specified purposes and under specified conditions. (Unemployment Insurance Code §1095)

This bill:

1. Requires EDD to work with employers to enhance the reporting of employment and earning data by employers, as required, consistent with federal law and regulations.
2. Requires EDD, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting process to minimize employer reporting burdens.
3. Beginning July 1, 2027, requires every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees on behalf of one or more employers, to include in the report of wages required by Section 1088 information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in a format approved by EDD.
4. Authorizes the director to require the data on hours worked to be submitted separately from the report of wages and may require the information to be reported more frequently than quarterly, but not more frequently than once a month.
5. Requires the information reported to be filed electronically, as specified.
6. Requires EDD, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data, as specified.
7. In adopting and developing the procedures, EDD is required to consult with DSS, DHCS, and stakeholders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and CalSAWS.
8. Requires EDD to work with CalSAWS to develop and implement the necessary system changes to implement the data sharing process to verify hours worked, as specified.
9. Requires EDD to work with the Office of the California Education Interagency Council related to the collection of employment data, as specified, for the purposes of supporting the council’s agendas, reports, work products, and resources.
10. Requires EDD to work with the California Workforce Development Board (CWDB) and the LWDA to implement the workforce program reporting requirements, as specified.
11. Authorizes EDD to work with the Office of Cradle-to-Career Data to support existing state data systems, dashboards, and reports related to the collection of employment data, as specified.
12. Requires EDD to use existing federal and state grant funds to the extent available.
13. Requires EDD to implement this section on or before July 1, 2027, except that EDD must begin the data sharing process to verify hours worked, as specified, on January 1, 2028, or when EDD notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
14. Permits the use of any information in the EDD Director’s possession, on or before January 1, 2028, to enable DSS and DHCS to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.
    1. Requires EDD to consult with DSS, DHCS, and stakeholders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and CalSAWS.
15. Permits the use of any information in the EDD Director’s possession, on or before January 1, 2028, to enable the Office of the California Education Interagency Council to access any relevant wage data necessary for the purposes of supporting the council’s agendas, reports, work products, and resources.
16. Defines the following terms:
17. “Hours worked” means the total hours worked by each worker each month. The employer may report 40 hours worked for each week any duties were performed by a full-time employee and shall report hours paid or a reasonable estimate of the hours worked for each week duties were performed by a part-time employee.
18. “Occupation” means an occupation listed in the United States Bureau of Labor Statistics’ Standard Occupational Classification system or the job title of each worker.
19. “Worker type” means the salaried or hourly, and full-time, part-time, intern, or apprentice status of each worker.
20. Provides that this act is known as Better Data, Better Coverage, Better California Act.
21. Makes several findings and declarations.

Background

EDD wage reporting and the base wage file. The Employment Development Department (EDD) administers Unemployment Insurance (UI), Disability Insurance (DI), and Paid Family Leave (PFL) programs. EDD also provides employment service programs and collects the state's labor market information and employment data. Employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. As part of the UI, DI, and PFL benefit program administration, EDD is also responsible for gathering and maintaining information in the base wage file. The base wage file assists in determining benefit program eligibility, distributing benefits, and minimizing fraud in the distribution of benefits.^[1]

In California, the base wage file includes employee first and last name, social security number, total subject wages, wage plan code, total personal income tax (PIT) wages, and total PIT withheld of each employee in California recorded separately for each employer on a quarterly basis. Base wage file data is reported from employers to EDD’s Tax Branch on a quarterly basis and stored securely by EDD to protect confidentiality. The base wage file is also an administrative data source for workforce program performance analysis and evaluation. The base wage file contains employment and earnings data for the time before and after workforce programs, and it allows analysts to compare employment and earnings for participants to individuals who are similar but did not participate in workforce programs.

EDD currently shares base wage file data, but only with specified state agencies and for specific allowable purposes through UI Code Section 1095 that outline what the data can and cannot be used for.^[2] UI Code Section 1095 requires the EDD Director to permit the use of any information in their possession to the extent necessary, for the specified purposes, and allows them to requirement reimbursement for all direct costs incurred.

SB 755 Report. In 2022, SB 755 (Roth, Chapter 815, Statutes of 2022) was signed, which required EDD and CWDB to work collaboratively to create a plan that identifies the costs and implementation timelines to measure, analyze, and report on employment and earnings outcomes for individuals who received job training services through specific programs, including the Workforce Innovation and Opportunity Act (WIOA) Title 1 managed by EDD and all programs managed by CWDB.

As the SB 755 report points out, there have been discussions at the federal and state level that have identified limitations within existing base wage files if data is used for program evaluation and research. For instance, the report states, “only ‘quarterly earnings’ are available on employees. Without understanding hours paid and total compensation to arrive at an hourly wage, it can be challenging to understand variation in earnings across employees. When earnings are particularly low, it is not clear if this is driven by low wages, low hours worked, or both. It is also not feasible to compare earnings to a regional living wage when the quarterly earnings are not accompanied with location data, such as employee’s region (residence or work site). In addition, it is not possible to determine if job training participants are placed in a ‘training-related job’ when there is no data related to occupation in the base wage file and limited information regarding the training services delivered in the participant data system.” The report further claims that these limitations affect the type of performance analysis and evaluation, as well as broader research, that is feasible when relying on the base wage file.

EDD also reported that a growing number of states have implemented data enhancements to their base wage file systems. The most common data elements collected by other states at the time of the SB 755 report were hours worked (eight states, plus the District of Columbia), occupation or job title (seven states, plus the U.S. Virgin Islands), and job location (eight states). Some states (Connecticut, Indiana, Nebraska, Mississippi) had recently adopted three or more data elements, which, at the time the report was released, were in various phases of planning or implementation. At least six states (Massachusetts, Minnesota, Nebraska, Oregon, Rhode Island, Washington) in addition to the District of Columbia had collected data on the hours worked by their employees. Five states (Alaska, Indiana, Mississippi, Nebraska, Washington) are collecting employee occupation and/or job title from the employer’s quarterly wage reports.

SB 1054, in part, aims to implement those recommendations to require additional data collected by employers (hours worked and employee occupation/job title) in their base wage file.

Who reports wages to EDD? As mentioned earlier, employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. This bill requires every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees on behalf of one or more employers, to include in the base wage file information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in a format approved by EDD. Under the proposed language in this bill, employers with less than 10 employees would not have to report the additional data. It is also unclear who would be captured under “individual or organizations that, as an agent, reports wages on a total of 10 or more employees” as these individuals or organizations do not currently have to report any wages to EDD, thus creating new reporters. As the bill moves forward, the author may wish to consider whether to limit the bill with the employers that currently do have a requirement to report wages to EDD.

[NOTE: See the Senate Labor, Public Employment and Retirement Committee analysis for detailed background on this bill.]

Related/Prior Legislation

AB 1098 (Fong, Chapter 446, Statutes of 2025) established the California Education Interagency Council within the Government Operations Agency to align education and workforce systems, support adult skill development, and address the changing nature of work and the economy. The Council would adopt strategic and workforce plans, issue recommendations to the Governor and Legislature, and, upon appropriation, create a faculty and employer advisory committee. This bill also created the Office of the California Education Interagency Council (managing entity) as a neutral administrative body.

SB 638 (Padilla, Chapter 457, Statutes of 2025) established a new statewide coordinating entity, the California Education Interagency Council (Council), to strengthen alignment of career technical education (CTE) and workforce development efforts.

SB 755 (Roth, Chapter 815, Statutes of 2022) required EDD to work with the CWDB to measure and report specified information regarding aggregate labor market outcomes of individuals receiving training services through the workforce system. This bill required, among other things, that the board and department create a plan to use existing data to match relevant employee occupational data, employee place of employment data, and employee hours worked data, to persons who enroll in job training services, and to outline various objectives. This bill required the board and department, upon appropriation by the Legislature, to implement the plan, and within 2 years of the appropriation, to summarize and provide an initial report of their findings to specified committees of the Legislature.

SB 753 (Roth, Chapter 550, Statutes of 2021) required among other things, the director of EDD to permit the use of specified wage data with the CWDB in order to assist the board in its obligation to evaluate program outcomes for the grant programs it administers.

AB 1245 (Cooley, Chapter 222, Statutes of 2016) required employers with 10 or more employees to file all reports and returns, and remit all contributions for unemployment insurance premiums to EDD electronically, as specified. Beginning on January 1, 2018, this bill extends the application of these electronic filing requirements to all employers.

AB 2148 (Mullin, Chapter 385, Statutes of 2014) required the California Workforce Investment Board (CWIB) to assist the Governor in the development of an annual workforce metrics dashboard to measure investment in workforce development, as specified.

FISCAL EFFECT: Appropriation: No Fiscal Com.: Yes Local: Yes

According to Senate Appropriations Committee:

• The bill’s administrative costs to the Employment Development Department (EDD) have yet to be identified, but would likely reach the low tens of millions of dollars minimally (See Staff Comments regarding funding source).
• The Department of Social Services (DSS) indicates that it would incur one-time costs of up to $600,000, and ongoing costs of $435,000 to implement the provisions of the bill. (General Fund).
• The Office of Cradle to Career Data (C2) indicates that it would incur ongoing costs of $373,000 to collaborate with EDD and accommodate the bill’s increased data frequency (General Fund).
• Costs to the Department of Health Care Services (DHCS) and the Education Interagency Council (EIC) have yet to be determined, but combined would likely, at a minimum, reach the hundreds of thousands of dollars (General Fund).

SUPPORT: (Verified 5/14/26)

California Competes: Higher Education for a Strong Economy (Co-Source)
California Edge Coalition (Co-Source)
UNITE-LA (Co-Source)
All Home
Bay Area Council
Blu Educational Foundation
Building Skills Partnership
California Association of Food Banks
California In-Home Supportive Services Consumer Alliance
California State Association of Counties
California Workforce Association
Ceo Leadership Alliance Orange County
Coalition of California Welfare Rights Organization
Coalition of California Welfare Rights Organizations
Economic Security Project Action
EdTrust-West
Inland Empire Health Plan Foundation
Jewish Vocational Service
Jobs for the Future
Jobtrain
JVS Bay Area
JVS SoCal
Little Hoover Commission
National Talent Collaborative
Northern California College Promise Coalition
Parent Institute for Quality Education
Solano County Democratic Central Committee
Strada Education Foundation
The Institute for College Access & Success
Tipping Point Community
University of California Student Association
Western Center on Law & Poverty
Yolo County Commission on Aging and Adult Services
Yolo County In-Home Supportive Services Advisory Committee
Young Invincibles

OPPOSITION: (Verified 5/14/26)

City of LA Verne

ARGUMENTS IN SUPPORT: According to one of the bill’s co-sponsors, California Edge Coalition, “SB 1054 is a practical step that strengthens California’s ability to evaluate whether skills training and education programs are leading to real employment outcomes. Today, the core wage file largely captures quarterly earnings and employer identifiers, but not the hours worked metric that is essential for understanding job quality and program-to-employment results. By adding hours worked and occupation, California will be better positioned to measure job placement and wage progression, identify workforce shortages, and improve the alignment of training investments with labor market demand. This builds on the state’s interest in more meaningful workforce outcomes measurement and supports statewide alignment efforts, including the Cradle-to-Career Data System and the California Education Interagency Council. […]

Additionally, SB 1054 helps California meet new federal work verification requirements for essential safety net programs. New federal rules now require states to verify that applicants work 80 hours per month for Medicaid and SNAP. Without timely, reliable hours worked data, working families may be forced into duplicative paperwork and face avoidable delays, errors, and benefit disruptions. An estimated 840,000 people could lose their CalFresh benefits if they are unable to verify meeting the work requirement.

SB 1054 enables the state to support automated eligibility determinations by collecting needed information directly from employers, helping eligible Californians keep their health coverage and nutrition assistance while reducing administrative strain on counties.”

ARGUMENTS IN OPPOSITION: According to the City of La Verne, opponents of this measure, “SB 1054 is intended to address gaps in the state’s existing wage data system by requiring employers to report additional information such as hours worked and occupation, largely to support workforce program evaluation and to comply with new federal work verification requirements tied to Medi-Cal and CalFresh eligibility.

However, this approach places a substantial and ongoing administrative burden on employers to solve a state-level data deficiency. Employers would be required to implement new tracking systems, report more frequently, and provide detailed employee-level data, all while the State expands data sharing across multiple agencies and programs. This represents an overreach that shifts responsibility away from the State and onto employers without sufficient safeguards or funding.

Additionally, the bill dramatically expands the collection and distribution of sensitive employment data, increasing the risk of data misuse, security vulnerabilities, and unintended consequences for workers. While intended to streamline eligibility verification, the scale of data collection and interagency access raises serious concerns about privacy and long-term data management.

SB 1054 prioritizes expansive data collection over practical implementation, creating a broad, one size-fits-all mandate that imposes significant costs and risks on employers with uncertain benefits.”

Prepared by: Jazmin Marroquin / L., P.E. & R. / (916) 651-1556

5/14/26 16:40:15

**** END ****

1. SB 755 (2022) Expanding Workforce Performance Analysis and Employer Quarterly Wage Reports, Final Report to Legislature. EDD, CWDB, LWDA, https://edd.ca.gov/siteassets/files/about_edd/sb-755-report---expanding-workforce-performance-analysis-and-employer-quarterly-wage-reports.pdf ↑

2. For instance, UI Code Section 1095 authorizes CWDB and other stakeholders to access any relevant quarterly wage data necessary for the evaluation and reporting of their respective program performance outcomes. ↑

SENATE COMMITTEE ON

Senator Sabrina Cervantes, Chair

2025 - 2026 Regular Session

SB 1054 (Cabaldon) - Unemployment insurance: reporting requirements

Bill Summary:

SB 1054 would require specified employers and other affected entities to also report total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified.

Fiscal Impact:

• The bill’s administrative costs to the Employment Development Department (EDD) have yet to be identified, but would likely reach the low tens of millions of dollars minimally (See Staff Comments regarding funding source).
• The Department of Social Services (DSS) indicates that it would incur one-time costs of up to $600,000, and ongoing costs of $435,000 to implement the provisions of the bill. (General Fund).
• The Office of Cradle to Career Data (C2) indicates that it would incur ongoing costs of $373,000 to collaborate with EDD and accommodate the bill’s increased data frequency (General Fund).
• Costs to the Department of Health Care Services (DHCS) and the Education Interagency Council (EIC) have yet to be determined, but combined would likely, at a minimum, reach the hundreds of thousands of dollars (General Fund).

Backround:

EDD administers the State’s Unemployment Insurance (UI), Disability Insurance (DI), and Paid Family Leave (PFL) programs. The department also provides employment service programs and collects the state's labor market information and employment data. Employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. As part of the UI, DI, and PFL benefit program administration, EDD is also responsible for gathering and maintaining information in the base wage file. The base wage file assists in determining benefit program eligibility, distributing benefits, and minimizing fraud in the distribution of benefits.

Currently, the base wage file includes employee first and last name, social security number, total subject wages, wage plan code, total personal income tax (PIT) wages, and total PIT withheld of each employee in California recorded separately for each employer on a quarterly basis. The base wage file is also an administrative data source for workforce program performance analysis and evaluation. The base wage file contains employment and earnings data for the time before and after workforce programs, and it allows analysts to compare employment and earnings for participants to individuals who are similar but did not participate in workforce programs.

EDD currently shares base wage file data, but only with specified state agencies and for specific allowable purposes authorized by current law. UI Code Section 1095 outlines what the data can and cannot be used to do. More generally, UI Code Section 1095 requires EDD to permit the use of any information in their possession to the extent necessary, for the specified purposes, and allows them to requirement reimbursement for all direct costs incurred.

In 2022, SB 755 (Roth, 2022) required EDD and CWDB to work collaboratively to (1) create a plan that identifies the costs and implementation timelines to measure, analyze, and (2) report on employment and earnings outcomes for individuals who received job training services through specific programs, including the Workforce Innovation and Opportunity Act (WIOA) Title 1 managed by EDD and all programs managed by CWDB.

As the SB 755 report notes, there have been discussions at the federal and state level that have identified limitations within existing base wage files if data is used for program evaluation and research. For instance, the report states, “only ‘quarterly earnings’ are available on employees. Without understanding hours paid and total compensation to arrive at an hourly wage, it can be challenging to understand variation in earnings across employees. When earnings are particularly low, it is not clear if this is driven by low wages, low hours worked, or both. It is also not feasible to compare earnings to a regional living wage when the quarterly earnings are not accompanied with location data, such as employee’s region (residence or work site). In addition, it is not possible to determine if job training participants are placed in a ‘training-related job’ when there is no data related to occupation in the base wage file and limited information regarding the training services delivered in the participant data system.” The report further claims that these limitations affect the type of performance analysis and evaluation, as well as broader research, that is feasible when relying on the base wage file.

Federal legislation (H.R. 1, 2025) resulted in significant changes to the State’s Medi-Cal and CalFresh programs. Currently, Medi-Cal does not require beneficiaries to work in order to be eligible for coverage; however, beginning January 2027, H.R. 1 requires most able-bodied, childless adults in Medicaid (generally 19-64 year olds who received coverage through the 2014 Affordable Care Act expansion) to complete at least 80 hours per month of work, education, or community service. This requirement does not apply to certain exempt groups, and states can provide additional exceptions for short-term hardship such as living in high-unemployment counties. The Legislative Analyst’s Office (LAO) estimates that, after exemptions, the requirement will apply to around 3.5 million Californians; the LAO further estimates that the federal policy change could result in disenrollments of around 1 to 2 million individuals, both from insufficient hours of engagement as well as administrative burden.

Additionally, able-bodied adults without dependents generally are limited to three months of CalFresh assistance in a three-year period unless they work or participate in qualifying activities for at least 20 hours per week. According to the LAO, until recently, California has had a statewide waiver exempting all CalFresh enrollees from the requirement based on economic conditions in the State. H.R. 1 expands the work requirement by (1) applying it to adults through age 64, rather than 54, (2) limiting a dependent-child exemption to adults caring for children under 14, rather than under 18, (3) eliminating exemptions for former foster youth, veterans, and homeless individuals, and (4) tightening rules for waivers based on economic conditions, ending California’s statewide waiver. With these changes, the administration estimates that about 840,000 individuals will become subject to the work requirement beginning June 2026 and will not qualify for an exemption. Of these, about 660,000 are estimated to not meet the requirement, thus becoming at risk of losing food assistance.

Proposed Law:

This bill, among other things, would do the following:

• Require EDD to work with employers to enhance the reporting of employment and earning data, as specified, and, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting processes.
• Require, beginning July 1, 2027, every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, as specified, to include in the report of wages, information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, as provided.
• Require EDD, on or before July 1, 2027, to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, and to enable access to relevant wage data, as specified.
• Require EDD to work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes to implement the data sharing process to verify hours worked for those public benefits.
• Require or authorize EDD to work with other specified state agencies relating to reporting requirements on workforce and employment.
• Require EDD to use existing federal and state grant funds to the extent available and to implement the bill’s provisions on or before July 1, 2027, except that, the bill would require the department to begin the data sharing process to verify hours worked for the public benefits on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
• Require EDD, on or before January 1, 2028, to enable DSS and DCHS to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, as prescribed.
• Require EDD, on or before January 1, 2028, to enable the Office of the California Education Interagency Council to access any relevant wage data necessary for the purposes of supporting the council’s agendas, reports, work products, and resources.

Related Legislation:

• AB 1098 (Fong, Chapter 446, Statutes of 2025) established EIC within the Government Operations Agency to align education and workforce systems, support adult skill development, and address the changing nature of work and the economy. The Council would adopt strategic and workforce plans, issue recommendations to the Governor and Legislature, and, upon appropriation, create a faculty and employer advisory committee. This bill also created the Office of the California Education Interagency Council (managing entity) as a neutral administrative body.
• SB 638 (Padilla, Chapter 457, Statutes of 2025) established a new statewide coordinating entity, the California Education Interagency Council (Council), to strengthen alignment of career technical education (CTE) and workforce development efforts.
• SB 755 (Roth, Chapter 815, Statutes of 2022) required EDD to work with the CWDB to measure and report specified information regarding aggregate labor market outcomes of individuals receiving training services through the workforce system. This bill required, among other things, that the board and department create a plan to use existing data to match relevant employee occupational data, employee place of employment data, and employee hours worked data, to persons who enroll in job training services, and to outline various objectives. This bill required the board and department, upon appropriation by the Legislature, to implement the plan, and within 2 years of the appropriation, to summarize and provide an initial report of their findings to specified committees of the Legislature.
• SB 753 (Roth, Chapter 550, Statutes of 2021) required among other things, the director of EDD to permit the use of specified wage data with the CWDB in order to assist the board in its obligation to evaluate program outcomes for the grant programs it administers.
• AB 2148 (Mullin, Chapter 385, Statutes of 2014) required the California Workforce Investment Board (CWIB) to assist the Governor in the development of an annual workforce metrics dashboard to measure investment in workforce development, as specified.

Staff Comments:

As part of the SB 755 report, EDD noted that a growing number of states have implemented data enhancements to their base wage file systems. The most common data elements collected by other states at the time of the SB 755 report were hours worked, occupation or job title, and job location. This bill would partially implement the SB 755 report’s recommendations to require additional data collected by employers (hours worked and employee occupation/job title) in their base wage file. Additionally, it would help the State meet the new federal work verification requirements related to Med-Cal and CalFresh benefits.

As noted above, the bill would require EDD to perform its workload using federal and state grant funds to the extent available. The General Fund would be likely be required to make up any shortfall.

Any local government costs resulting from the mandate in this measure are not state-reimbursable because the mandate only involves the definition of a crime or the penalty for conviction of a crime.

-- END --

SENATE COMMITTEE ON LABOR, PUBLIC EMPLOYMENT AND RETIREMENT

Senator Lola Smallwood-Cuevas, Chair

2025 - 2026 Regular

Bill No: SB 1054 Hearing Date: March 25, 2026

SUBJECT: Unemployment insurance: reporting requirements

KEY ISSUE

This bill requires every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees, as specified, to also report total monthly wage, industry, occupation, worker type, and hours worked for each employee, as specified, on or before July 1, 2027.

This bill also requires the Employment Development Department (EDD) to:

• On or before July 1, 2027, 1) work with employers to enhance the reporting of employment and earning data by employers, as specified, 2) adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verification for public benefits, as specified, and consult with specified stakeholders; 3) work with the California Statewide Automated Welfare System (CalSAWS) to develop and implement the necessary system changes, as specified; 4) work with the Office of the California Education Interagency Council related to the collection of employment data, as specified; 5) work with the California Workforce Development Board (CWDB) and the Labor and Workforce Development Agency (LWDA) to implement specified workforce program reporting requirements; 6) work with the Office of Cradle-to-Career (C2C) Data, as specified; and 7) use existing federal and state grant funds to the extent available.
• On January 1, 2028, begin the data sharing process to verify hours worked for the public benefits, as specified.

ANALYSIS

Existing law:

1. Establishes the EDD within the LWDA. EDD is responsible for, among other duties, the administration of the Unemployment Insurance (UI) and Disability Insurance (DI) programs. (Unemployment Insurance Code §301)
2. Establishes the UI program as a joint state/federal program, administered by EDD that provides weekly unemployment insurance payments for workers who lose their job through no fault of their own. Eligibility for benefits requires that the claimant be able to work, available for work, be seeking work, and be willing to accept a suitable job. (Unemployment Insurance Code §§100-144, 301-456)
3. Requires, among other things, an employer to file a report of contributions, a quarterly return, and a report of wages paid to the employer’s worker, as specified. (Unemployment Insurance Code §1088)
   1. Requires all employers to file the report of contributions, quarterly return, and report of wage electronically. (Unemployment Insurance Code §1088 (h)(2))
   2. Authorizes employers to request a waiver from the electronic filing requirements, as specified. (Unemployment Insurance Code §1088(h)(3))
4. Requires, in addition to information reported with Unemployment Insurance Code Section 1088, an employer to submit information on new employees, and among other things, a report containing the following:
   1. The name, address, and social security number of the employees.
   2. The employer’s name, address, state employer identification number (if one has been issued), and identifying number assigned to the employer under Section 61095 of the Internal Revenue Code of 1986.
   3. The first date the employee worked. (Unemployment Insurance Code §1088.5)
5. Authorizes EDD to share wage and employment data, under specified conditions, for a variety of purposes, including the evaluation of workforce programs, as specified, which enumerates the programs for which data can be shared. (Unemployment Insurance Code §1095)

This bill:

1. Requires EDD to work with employers to enhance the reporting of employment and earning data by employers, as required, consistent with federal law and regulations.
2. Requires EDD, where feasible, to align and streamline definitions and requirements for the quarterly report of wages, deploy user-friendly application programming interfaces, and implement other means to simplify reporting process to minimize employer reporting burdens.
3. Beginning July 1, 2027, requires every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees on behalf of one or more employers, to include in the report of wages required by Section 1088 information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in a format approved by EDD.
4. Authorizes the director to require the data on hours worked to be submitted separately from the report of wages and may require the information to be reported more frequently than quarterly, but not more frequently than once a month.
5. Requires the information reported to be filed electronically, as specified.

1. On or before July 1, 2027, requires EDD to adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.
2. In adopting and developing the procedures, requires EDD to consult with the State Department of Social Services, the State Department of Health Care Services, and interest holders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and the CalSAWS.
3. Requires EDD to work with CalSAWS to develop and implement the necessary system changes to implement the data sharing process to verify hours worked, as specified.
4. Requires EDD to work with the Office of the California Education Interagency Council related to the collection of employment data for the purposes of supporting the council’s agendas, reports, work products, and resources.
5. Requires EDD to work with the CWDB and the LWDA to implement the workforce program reporting requirements contained in Section 14017.1.
6. Authorizes EDD to work with the C2C Data to support existing state data systems, dashboards, and reports related to the collection of employment data.
7. Requires EDD to use existing federal and state grant funds to the extent available.
8. Requires EDD to implement this section on or before July 1, 2027, except that EDD must begin the data sharing process to verify hours worked, as specified, on January 1, 2028, or when EDD notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.
9. Defines the following terms:
10. “Hours worked” means the total hours worked by each worker each month. The employer may report 40 hours worked for each week any duties were performed by a full-time employee and shall report hours paid or a reasonable estimate of the hours worked for each week duties were performed by a part-time employee.
11. “Occupation” means an occupation listed in the United States Bureau of Labor Statistics’ Standard Occupational Classification system or the job title of each worker.
12. “Worker type” means the salaried or hourly, and full-time, part-time, intern, or apprentice status of each worker.
13. Provides that this act is known as Better Data, Better Coverage, Better California Act.
14. Makes several findings and declarations.

COMMENTS

1. Background:

EDD Wage Reporting and the Base Wage File

The Employment Development Department (EDD) administers Unemployment Insurance (UI), Disability Insurance (DI), and Paid Family Leave (PFL) programs. EDD also provides employment service programs and collects the state's labor market information and employment data. Employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. As part of the UI, DI, and PFL benefit program administration, EDD is also responsible for gathering and maintaining information in the base wage file. The base wage file assists in determining benefit program eligibility, distributing benefits, and minimizing fraud in the distribution of benefits.^[1]

In California, the base wage file includes employee first and last name, social security number, total subject wages, wage plan code, total personal income tax (PIT) wages, and total PIT withheld of each employee in California recorded separately for each employer on a quarterly basis. Base wage file data is reported from employers to EDD’s Tax Branch on a quarterly basis and stored securely by EDD to protect confidentiality. The base wage file is also an administrative data source for workforce program performance analysis and evaluation. The base wage file contains employment and earnings data for the time before and after workforce programs, and it allows analysts to compare employment and earnings for participants to individuals who are similar but did not participate in workforce programs.

EDD currently shares base wage file data, but only with specified state agencies and for specific allowable purposes through UI Code Section 1095 that outline what the data can and cannot be used for.^[2] UI Code Section 1095 requires the EDD Director to permit the use of any information in their possession to the extent necessary, for the specified purposes, and allows them to requirement reimbursement for all direct costs incurred.

SB 755 Report

In 2022, SB 755 (Roth, Chapter 815, Statutes of 2022) was signed, which required EDD and CWDB to work collaboratively to create a plan that identifies the costs and implementation timelines to measure, analyze, and report on employment and earnings outcomes for individuals who received job training services through specific programs, including the Workforce Innovation and Opportunity Act (WIOA) Title 1 managed by EDD and all programs managed by CWDB.^[3]

As the SB 755 report points out, there have been discussions at the federal and state level that have identified limitations within existing base wage files if data is used for program evaluation and research. For instance, the report states, “only ‘quarterly earnings’ are available on employees. Without understanding hours paid and total compensation to arrive at an hourly wage, it can be challenging to understand variation in earnings across employees. When earnings are particularly low, it is not clear if this is driven by low wages, low hours worked, or both. It is also not feasible to compare earnings to a regional living wage when the quarterly earnings are not accompanied with location data, such as employee’s region (residence or work site). In addition, it is not possible to determine if job training participants are placed in a ‘training-related job’ when there is no data related to occupation in the base wage file and limited information regarding the training services delivered in the participant data system.” The report further claims that these limitations affect the type of performance analysis and evaluation, as well as broader research, that is feasible when relying on the base wage file.

EDD also reported that a growing number of states have implemented data enhancements to their base wage file systems. The most common data elements collected by other states at the time of the SB 755 report were hours worked (eight states, plus the District of Columbia), occupation or job title (seven states, plus the U.S. Virgin Islands), and job location (eight states). Some states (Connecticut, Indiana, Nebraska, Mississippi) had recently adopted three or more data elements, which, at the time the report was released, were in various phases of planning or implementation. At least six states (Massachusetts, Minnesota, Nebraska, Oregon, Rhode Island, Washington) in addition to the District of Columbia had collected data on the hours worked by their employees. Five states (Alaska, Indiana, Mississippi, Nebraska, Washington) are collecting employee occupation and/or job title from the employer’s quarterly wage reports.

SB 1054, in part, aims to implement those recommendations to require additional data collected by employers (hours worked and employee occupation/job title) in their base wage file.

H.R. 1

In July 2025, the President signed H.R. 1— also known as the ‘One Big Beautiful Bill Act’ —which introduced significant changes to Medi-Cal and CalFresh.^[4] The changes made by H.R. 1 are being phased in, although some changes are already in effect. The Legislative Analyst’s Office (LAO) prepared a report to the Legislature in February 2026 highlighting the impacts of H.R. 1. Currently, Medi-Cal does not require beneficiaries to work in order to be eligible for coverage but beginning January 2027, H.R. 1 requires most able-bodied, childless adults in Medicaid (generally 19-64 year olds who received coverage through the 2014 Affordable Care Act expansion) to complete at least 80 hours per month of work, education, or community service.^[5] This requirement does not apply to certain exempt groups, and states can provide additional exceptions for short-term hardship such as living in high-unemployment counties. According to the LAO, after exemptions, the requirement is estimated to apply to around 3.5 million people and they estimate this policy could result in disenrollments of around 1 to 2 million people, both from insufficient hours of engagement as well as administrative burden.

Additionally, able-bodied adults without dependents generally are limited to three months of CalFresh assistance in a three-year period unless they work or participate in qualifying activities for at least 20 hours per week. According to the LAO, until recently, California has had a statewide waiver exempting all CalFresh enrollees from the requirement based on economic conditions in the state. H.R. 1 expands the work requirement by applying it to adults through age 64, rather than 54; limiting a dependent-child exemption to adults caring for children under 14, rather than under 18; eliminating exemptions for former foster youth, veterans, and homeless individuals; and tightening rules for waivers based on economic conditions, ending California’s statewide waiver.^[6] With these changes, the administration estimates that about 840,000 individuals will become subject to the work requirement beginning June 2026 and will not qualify for an exemption. Of these, about 660,000 are estimated to not meet the requirement, thus becoming at risk of losing food assistance. The changes made to California’s essential safety net programs by H.R. 1 are likely to put millions of households and families at risk of losing some or all their Medi-Cal coverage or food assistance.

2. Need for this bill?

According to the author, “The current wage file collected by EDD only includes quarterly earnings and employer ID numbers. As H.R. 1 threatens to reduce Californians’ benefit access, the need to collect employees' hours worked is critical to ensure that California residents do not lose access to their Medicaid and SNAP benefits. As of now, the State relies on a shared-services access contract with Equifax where they provide employment and income data to the Department of General Services at an exorbitant cost to verify eligibility.

Additionally, California will soon require more precise data on labor market outcomes to administer the new Workforce Pell program and enable the California Education Interagency Council to conduct analyses that support planning efforts to better align education pathways with workforce outcomes in sectors critical to California’s economy. A lack of data on employee’s occupation will inhibit these efforts.”

3. Committee Comments:

Who reports wages to EDD?

As mentioned earlier, employers of all sizes are required to file a report of contributions, quarterly returns, and a report of wages paid to their employees to EDD. This bill requires every employer with 10 or more employees and every individual or organization that, as an agent, reports wages on a total of 10 or more employees on behalf of one or more employers, to include in the base wage file information on total monthly wage, industry, occupation, worker type, and hours worked for each employee, in a format approved by EDD. Under the proposed language in this bill, employers with less than 10 employees would not have to report the additional data. It is also unclear who would be captured under “individual or organizations that, as an agent, reports wages on a total of 10 or more employees” as these individuals or organizations do not currently have to report any wages to EDD, thus creating new reporters. As the bill moves forward, the author may wish to consider whether to limit the bill with the employers that currently do have a requirement to report wages to EDD.

EDD’s base wage file data and data sharing requirements

EDD can share base wage file data, but only with specified agencies and for limited purposes. UI Code Section 1095 outlines what the data can and cannot be used for.^[7] In fact, the SB 755 report recommends that if policymakers wish to expand access to base wage data for purposes beyond those stated in UI Code Section 1095, new legislation would be required to update UI Code Section 1095.

This bill seeks to require EDD to share the number of hours worked by each worker and other necessary employment data to support employment-related verification for eligibility for public benefits including Medi-Cal and CalFresh benefits.

The Department of Health Care Services (DHCS), the state entity that administers Medi-Cal, has explicit authorization under UI Code Section 1095 to obtain information from EDD regarding employee wages for the purpose of verifying or determining eligibility of specified state health subsidy programs.^[8] The California Department of Social Services (CDSS), which administers CalFresh, currently also has explicit authorization under UI Code Section 1095 to access specific EDD wage data,^[9] but CDSS is not specifically authorized to access the data to determine eligibility for the purposes proposed under this bill. The Office of the California Education Interagency Council, housed within the Government Operations Agency, which was established to align education and workforce systems, support adult skill development, and address the changing nature of work and the economy, does not have express authorization to obtain EDD wage data under UI Code Section 1095. However, the Cradle-to-Career Data System, which provides data-informed tools to help students reach their college and career goals and deliver information on education and workforce outcomes, is authorized to receive employment and earnings data from EDD.^[10]

For clarity and consistency, the data sharing requirements under this bill should be moved to UI Code Section 1095 where the other EDD data sharing provisions currently exist, therefore the author has agreed to committee amendments that instead cross reference and add the data sharing provisions to UI code section 1095. A mock-up is below:

UIC 1088.3 (d) On or before July 1, 2027, the department shall adopt and develop appropriate procedures for the sharing of hours worked and other necessary employment data pursuant to Section 1095 (as) and Section 1095 (at). to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program. In adopting and developing the procedures, the department shall consult with the State Department of Social Services, the State Department of Health Care Services, and interest holders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and the California Statewide Automated Welfare System (CalSAWS).

UIC 1088.3 (e) The department shall work with CalSAWS to develop and implement the necessary system changes to implement the data sharing process pursuant to Section 1095 (as) and Section 1095 (at) to verify hours worked as described in subdivision (d).

UIC 1088.3 (f) The department shall work with the Office of the California Education Interagency Council related to the collection of employment data pursuant to Section 1095 (as) and Section 1095 (at) for the purposes of supporting the council’s agendas, reports, work products, and resources. The department shall work with the California Workforce Development Board and the Labor and Workforce Development Agency to implement the workforce program reporting requirements contained in Section 14017.1 and shall provide any relevant necessary wage data, inclusive of subdivision (C) of this section, pursuant to Section 1095 (aj).

UIC 1088.3 (g) The department may work with the Office of Cradle-to-Career Data to support existing state data systems, dashboards, and reports related to the collection of employment data pursuant to Section 1095 (ap).

UIC 1088.3 (h) The department shall use existing federal and state grant funds to the extent available and shall implement this section on or before July 1, 2027, except that the department shall begin the data sharing process pursuant to Section 1095 (as) and Section 1095 (at) to verify hours worked as described in subdivision (d), on January 1, 2028, or when the department notifies the Legislature that CalSAWS can perform the necessary automation to implement the data sharing process, whichever is later.

UIC 1095 (as) (1) On or before January 1, 2028, to enable the State Department of Social Services, the State Department of Health Care Services to access hours worked and other necessary employment data to support employment-related verifications for initial eligibility for, and ongoing receipt of, public benefits, including, but not limited to, benefits pursuant to the Medi-Cal program and the CalFresh program.

(2) The department shall consult with the State Department of Social Services, the State Department of Health Care Services, and stakeholders, including, but not limited to, the Office of Cradle-to-Career Data, the County Welfare Directors Association of California, and the California Statewide Automated Welfare System (CalSAWS).

UIC 1095 (at) (1) On or before January 1, 2028, to enable the Office of the California Education Interagency Council to access any relevant wage data necessary for the purposes of supporting the Council’s agendas, reports, work products, and resources.

UIC 1095 (aj) (1) To enable the California Workforce Development Board, the Chancellor of the California Community Colleges, the Superintendent of Public Instruction, the Department of Rehabilitation, the State Department of Social Services, the Bureau for Private Postsecondary Education, the Department of Industrial Relations, the Division of Apprenticeship Standards, the Department of Corrections and Rehabilitation, the California Correctional Training and Rehabilitation Authority, the Employment Training Panel, and a chief elected official, as that term is defined in Section 3102(9) of Title 29 of the United States Code, to access any relevant quarterly wage data necessary for the evaluation and reporting of their respective program performance outcomes as required and permitted by various local, state, and federal laws pertaining to performance measurement and program evaluation, including responsibilities arising under Sections 14013, 14017.1, 14033, and 14042 of this code and Sections 2032 and 2038 of the Streets and Highways Code; the federal Workforce Innovation and Opportunity Act (Public Law 113-128); the workforce metrics dashboard pursuant to paragraph (1) of subdivision (i) of Section 14013; the Adult Education Block Grant Program consortia performance metrics pursuant to Section 84920 of the Education Code; the economic and workforce development program performance measures pursuant to Section 88650 of the Education Code; and the California Community Colleges Economic and Workforce Development Program performance measures established in Part 52.5 (commencing with Section 88600) of Division 7 of Title 3 of the Education Code. Disclosures under this subdivision shall comply with federal and state privacy laws that require the informed consent from program participants of city and county departments or agencies that administer public workforce development programs for the evaluation, research, or forecast of their programs regardless of local, state, or federal funding source.

4. Proponent Arguments:

According to the California EDGE Coalition, a co-sponsor of this bill:

“SB 1054 is a practical step that strengthens California’s ability to evaluate whether skills training and education programs are leading to real employment outcomes. Today, the core wage file largely captures quarterly earnings and employer identifiers, but not the hours worked metric that is essential for understanding job quality and program-to-employment results. By adding hours worked and occupation, California will be better positioned to measure job placement and wage progression, identify workforce shortages, and improve the alignment of training investments with labor market demand. This builds on the state’s interest in more meaningful workforce outcomes measurement and supports statewide alignment efforts, including the Cradle-to-Career Data System and the California Education Interagency Council.

SB 1054 would also help position California for Workforce Pell implementation. Under the U.S. Department of Education’s proposed Workforce Pell regulations, states may use an interim job-placement measure through the 2028-29 award year, but beginning in 2029-30 programs would need to demonstrate that completers are employed in the occupations for which the program prepares them, or in comparable occupations. The proposed transition period is intended to give states time to strengthen the administrative data systems needed to track occupational outcomes, and SB 1054 would help California make that progress now.

Additionally, SB 1054 helps California meet new federal work verification requirements for essential safety net programs. New federal rules now require states to verify that applicants work 80 hours per month for Medicaid and SNAP. Without timely, reliable hours worked data, working families may be forced into duplicative paperwork and face avoidable delays, errors, and benefit disruptions. An estimated 840,000 people could lose their CalFresh benefits if they are unable to verify meeting the work requirement.

SB 1054 enables the state to support automated eligibility determinations by collecting

needed information directly from employers, helping eligible Californians keep their health

coverage and nutrition assistance while reducing administrative strain on counties.”

5. Opponent Arguments:

None received.

6. Prior Legislation:

AB 1098 (Fong, Chapter 446, Statutes of 2025) established the California Education Interagency Council within the Government Operations Agency to align education and workforce systems, support adult skill development, and address the changing nature of work and the economy. The Council would adopt strategic and workforce plans, issue recommendations to the Governor and Legislature, and, upon appropriation, create a faculty and employer advisory committee. This bill also created the Office of the California Education Interagency Council (managing entity) as a neutral administrative body.

SB 638 (Padilla, Chapter 457, Statutes of 2025) established a new statewide coordinating entity, the California Education Interagency Council (Council), to strengthen alignment of career technical education (CTE) and workforce development efforts.

SB 755 (Roth, Chapter 815, Statutes of 2022) required EDD to work with the CWDB to measure and report specified information regarding aggregate labor market outcomes of individuals receiving training services through the workforce system. This bill required, among other things, that the board and department create a plan to use existing data to match relevant employee occupational data, employee place of employment data, and employee hours worked data, to persons who enroll in job training services, and to outline various objectives. This bill required the board and department, upon appropriation by the Legislature, to implement the plan, and within 2 years of the appropriation, to summarize and provide an initial report of their findings to specified committees of the Legislature.

SB 753 (Roth, Chapter 550, Statutes of 2021) required among other things, the director of EDD to permit the use of specified wage data with the CWDB in order to assist the board in its obligation to evaluate program outcomes for the grant programs it administers.

AB 1245 (Cooley, Chapter 222, Statutes of 2016) required employers with 10 or more employees to file all reports and returns, and remit all contributions for unemployment insurance premiums to EDD electronically, as specified. Beginning on January 1, 2018, this bill extends the application of these electronic filing requirements to all employers.

AB 2148 (Mullin, Chapter 385, Statutes of 2014) required the California Workforce Investment Board (CWIB) to assist the Governor in the development of an annual workforce metrics dashboard to measure investment in workforce development, as specified.

SUPPORT

California Competes: Higher Education for a Strong Economy (Co-sponsor)

California Edge Coalition (Co-sponsor)

UNITE-LA (Co-sponsor)

Bay Area Council

Blu Educational Foundation

California In-Home Supportive Services Consumer Alliance

CEO Leadership Alliance Orange County

Coalition of California Welfare Rights Organizations

EdTrust-West

Jewish Vocational Service

National Talent Collaborative

Strada Education Foundation

The Institute for College Access & Success

Western Center on Law & Poverty, INC.

Yolo County In-Home Supportive Services Advisory Committee

OPPOSITION

None received.

-- END --

1. SB 755 (2022) Expanding Workforce Performance Analysis and Employer Quarterly Wage Reports, Final Report to Legislature. EDD, CWDB, LWDA, https://edd.ca.gov/siteassets/files/about_edd/sb-755-report---expanding-workforce-performance-analysis-and-employer-quarterly-wage-reports.pdf ↑

2. For instance, UI Code Section 1095 authorizes CWDB and other stakeholders to access any relevant quarterly wage data necessary for the evaluation and reporting of their respective program performance outcomes. ↑

3. The CWDB assists the Governor in setting and guiding policy in workforce development. Workforce programs include a range of services delivered to Californians, including job training for unemployed and incumbent workers, apprenticeship and pre-apprenticeship, supportive services, and building employer partnerships. These programs aim to build workers’ skills and meet industry needs to support workers with entering career pathways where employment and earnings outcomes increase over time. ↑

4. Medi-Cal is California’s Medicaid program, and it provides health care for more than 14 million low-income people (around one-third of all Californians). CalFresh is California’s version of the Supplemental Nutrition Assistance Program (SNAP), and it provides federally funded food assistance to about 5.4 million low-income Californians. The State provides state-funded food assistance to about 60,000 additional low-income legally present noncitizens who do not qualify for federal CalFresh benefits. Most CalFresh enrollees (about 90%) are also enrolled in Medi-Cal. ↑

5. Key Impacts of H.R. 1 on Medi-Cal and CalFresh. Legislative Analyst’s Office. February 11, 2026. https://lao.ca.gov/handouts/health/2026/H.-R-1-Key-Impacts-021126.pdf ↑

6. According to the LAO, the state is seeking waivers under the tighter rules on a county-by-county basis and has obtained waivers in some counties. ↑

7. For instance, UI Code §1095 authorizes CWDB and other stakeholders to access any relevant quarterly wage data necessary for the evaluation and reporting of their respective program performance outcomes. ↑

8. Unemployment Insurance Code § 1095(ad) ↑

9. Unemployment Insurance Code § 1095(aj) ↑

10. Unemployment Insurance Code § 1095(ap) ↑