New York City has passed ordinances that will require employers with 200 or more employees working in New York City to report pay and demographic data annually. The law will also require the city to conduct a pay equity study.
Note: While New York City’s mayor vetoed the law on Nov. 7, 2025, the City Council overrode the veto on Dec. 4, 2025, and the law became effective immediately.
Pay data reporting
Ordinance Int. 982-2024-A will require covered employers to submit a pay data report on an annual basis. To assess coverage, employers should use the highest number of full-time, part-time or temporary workers who work for compensation at the same time during the reporting year.
The report must include:
· Detailed pay and demographic data that correspond with the categories required by the U.S. Equal Employment Opportunity Commission (EOC) in the EEO-1 component 2 reporting requirements for reporting years 2017 and 2018 (such as race, ethnicity and gender)
· A signed statement that confirms the submission of the pay data report and the accuracy of its information.
Note: Employers may choose to submit the report anonymously, provided the signed statement identifies the covered employer.
Int. 982-2024-A also allows New York City to modify the information required, including having reporting options that account for different gender identities. The report must also allow employers the option to provide explanatory remarks regarding the information in the report and must not require an employee’s personal information.
Pay equity study
A designated agency will use the pay data collected to assess compensation disparities based on race, gender or ethnicity. The agency will be charged with identifying industries where disparities exist and providing recommendations to address the inequities. The agency will publish its recommendations and data from the pay equity report in aggregate without disclosing employer or employee identities.
Timing
The timing and process for pay data reporting and the pay equity study are as follows[MG4] [MG5] :
· Within one year of the effective date (Dec. 4, 2025), the mayor must designate an agency to create a system to collect the required pay data reports and conduct a pay equity study.
· Within one year after the agency is designated, that agency must develop a standardized fillable form, which may be electronic, for employers to submit pay data reports.
· Within one year after the standardized form is published, and annually thereafter, covered employers must submit a pay report.
· Within one year after the pay equity reports are submitted, the designated agency, in collaboration with the New York City Commission on Gender Equity and other relevant agencies, will conduct a pay equity study.
Penalties
An employer found not to have submitted the signed statement will have a 30-day grace period to submit the required statement after being notified of noncompliance. Otherwise, the employer may have their noncompliance reported on the agency’s website.
An employer that is found to have violated the law may also face the following penalties:
· First violation: A written warning provided they fix the violation within 30 days, and if not, a civil penalty of $1,000.
· Subsequent violations: The civil penalty will increase to $5,000.
Next Steps
Employers should review their internal pay practices and prepare to collect and report the required pay data. Employers should also monitor additional guidance to address implementing these requirements.