On December 4, 2025, the New York City Council voted to override Mayor Eric Adams’s veto, effectively enacting two significant pieces of legislation regarding pay data reporting and pay equity studies.
These new laws, Int. 0982-2024-A and Int. 0984-2024-A, will impose extensive reporting obligations on large employers in New York City and mandate citywide pay equity studies based on the collected data.
Background
Initially passed by the City Council in October 2025, the bills were vetoed by Mayor Adams in November due to concerns regarding the complexity of the requirements. However, the Council’s recent override confirms the city’s commitment to increasing wage transparency and addressing pay disparities based on race, ethnicity, and gender.
Key Provisions of the New Laws
- Pay Data Reporting Requirements. Under the new law, private employers with 200 or more employees working in New York City will be required to submit annual pay data reports.
- Data Content. The reports must include compensation data and total hours worked, broken down by race, ethnicity, and sex.
- Format. The reporting structure will be modeled after the U.S. Equal Employment Opportunity Commission’s (EEOC) former “EEO-1 Component 2” reports from 2017 and 2018.
- Modifications. The designated city agency has the discretion to modify these requirements, including adding reporting options to account for different gender identities.
- Anonymity. Employers may submit the data anonymously; however, they must separately submit a signed statement attesting to the accuracy of the information.
- Annual Pay Equity Study. The collected data will be used by a designated city agency to conduct an annual pay equity study. This study will analyze the data to identify potential pay disparities across industries and demographic groups. The agency will publish the findings in an aggregate format that protects the confidentiality of individual employers and employees.
Implementation Timeline
While the laws are now enacted, immediate reporting is not required. The legislation outlines a phased implementation:
- Agency Designation. The mayor must designate an agency to administer the program by December 4, 2026.
- Form Development. The designated agency will have one year to develop and publish a standardized reporting form.
- First Report Due. Employers will be required to submit their first report one year after the standardized form is published, which is expected to push the first filing deadline to late 2027 or 2028.
Enforcement and Penalties
Non-compliance carries both financial and reputational risks:
- Cure Period. Employers who fail to file will receive a written warning and a 30-day period to cure the violation.
- Fines. Failure to comply after the cure period may result in a civil penalty of $1,000 for the first offense and $5,000 for subsequent offenses.
- Public Listing. The city agency will publish an annual list of non-compliant employers on its website.
Next Steps for Employers
Although the first reporting deadline is in the future, covered employers should begin preparing now:
- Assess Applicability: Determine if your organization meets the 200-employee threshold within New York City limits.
- Audit Current Data: Review your HRIS and payroll systems to ensure you are accurately capturing demographic data (race, ethnicity, gender) and compensation details that align with EEO-1 Component 2 standards.
- Monitor Regulatory Updates: Stay alert for the designation of the administering agency and the release of specific reporting guidance or forms.
- Consult Legal Counsel: Discuss the implications of these new requirements with employment counsel to ensure your data collection practices are compliant.
