By: HUB’s EB Compliance Team

San Francisco employers must submit their 2025 Employer Annual Reporting Form (ARF) to the OLSE by May 1, 2026.

On April 1, 2026, the San Francisco Office of Labor Standards Enforcement (OLSE) began accepting 2025 Annual Reporting Form submissions from covered employers. Compliance with the San Francisco Health Care Security Ordinance (SF HCSO) and Fair Chance Ordinance (FCO) must be reported through the online portal. The deadline for 2025 calendar year reporting is May 1, 2026. Employers should file their forms on time to ensure compliance.

Who must report?

Employers will need to determine whether they are covered in terms of employees who must be paid and whether they meet the FCO criteria for background check applications and requirements.

  • If a company has five (5) or more employees worldwide, with one (1) or more employees working at least eight hours per week in the City (including those who are working remotely while living in San Francisco), that company must submit the FCO reporting section.
  • For reporting to the SF HCSO, employers with 20 or more workers worldwide, with 1 or more employees in the City, who work 8 hours or more per week within San Francisco’s boundaries are counted. This year’s form is now live and ready for submission.

What you’ll need to report in the ARF

The ARF requires healthcare spending data for all four payroll quarters of 2025. Employers are encouraged to download the ARF Preview Form before beginning the reporting process, as the ARF website does not allow saving work in progress. Therefore, gathering all required information before beginning your submission enables a quicker and error-free submission. Before starting, ensure you have all the required information on hand or complete the ARF Preview form in advance:

  • Business Account Number
  • Name and Address
  • Business Type
  • Business Size
  • Covered Employees
  • Total healthcare spending
  • Surcharges that may have been received

The reports below will need the following information:

SF HCSO

  • Total number of people employed worldwide, as well as the number of employees employed per quarter.
  • Number of employees covered under the HCSO per quarter.
  • Healthcare expenditures made on behalf of covered employees, per quarter.
  • Any surcharges collected from customers to offset HCSO compliance costs.

SF FCO

The FCO reporting is included in the same ARF. Employers with five or more employees worldwide, and at least one employee working in San Francisco, must report.

  • Employer San Francisco Business Account Number (contact the OLSE if unsure).
  • Include all San Francisco workers — part-time, temporary, seasonal and telecommuters.
  • Report whether your job application asks about arrest or conviction history.
  • Background checks may only occur after a conditional offer of employment.
  • Report on how many people with a conviction history were hired in 2025.
  • If federal/state law governs your background check process, provide your industry exemption.

Exemptions

The ARF is a combined report and submission to OLSE to ensure employers doing business in the City comply with these ordinances. Exemptions from reporting apply if an employer meets specific criteria detailed below:

FCO

  • You are exempt from the FCO if you have fewer than 5 employees worldwide in each quarter of 2025 and do not have a City and County of San Francisco contract.
  • You are also exempt from the FCO if a federal or state law requires background checks for the specific job.

HCSO

  • You employed fewer than 20 people worldwide, and
  • Do not have employees physically working within San Francisco — including those working from home in San Francisco — during any quarter of 2025.

Don’t wait — late submissions carry risk!

The OLSE portal often stays open after the deadline, but late ARF submissions can have consequences. If your organization is audited, a missed deadline may result in an administrative penalty of up to $500 per quarter for each violation. We strongly recommend submitting the ARF on time.

Takeaways

Covered employers under the HCSO and FCO will want to ensure they file the SF ARF before the May 1, 2026, deadline to avoid penalties. The OLSE provides entities with assistance via phone, webinars, overviews and several resources to review, including the 2025_ARF_Instructions.pdf and the downloadable ARF preview form. Employers are encouraged to call the OLSE if they have any questions, as the OLSE will assist organizations with troubleshooting and compliance with the City's obligations.

To contact the OLSE regarding your obligations under the ordinance, please visit www.sfgov.org/olse/hcso
Health Care Security Ordinance
Email: [email protected]
Phone: 415-554-7892
Fair Chance Ordinance
Email: [email protected]
Phone: 415-554-5192

If you have any questions, please contact your HUB advisor. View more compliance articles in our Compliance Directory.

NOTICE OF DISCLAIMER

Neither Hub International Limited nor any of its affiliated companies is a law or accounting firm, and therefore they cannot provide legal or tax advice. The information herein is provided for general information only and is not intended to constitute legal or tax advice as to an organization’s or individual's specific circumstances. It is based on HUB International's understanding of the law as it exists on the date of this publication. Subsequent developments may result in this information becoming outdated or incorrect, and HUB International is not obliged to update it. You should consult an attorney, accountant or other legal or tax professional regarding the application of the general information provided here to your organization’s specific situation in light of your or your organization’s particular needs.