On October 9, 2025, the New York City Council passed two bills that would place new pay data reporting obligations on employers and require the city government to conduct a pay equity study.
The bills await action from Mayor Eric Adams, who has until November 8, 2025, to either sign or veto the bills before they become law by default.
New York City would become the fourth U.S. jurisdiction to mandate pay data reporting, following California, Illinois, and, most recently, Massachusetts, even as the Equal Employment Opportunity Commission (EEOC) has rolled back pay data reporting requirements at the federal level.
Pay Data Reporting Coming—Eventually
The first bill (Int. No. 0982-2024) (the “Pay Reporting Ordinance”) would require private employers in New York City with 200 or more employees to report employee pay information to the City government. The 200-employee headcount includes all employees employed in New York City, regardless of whether they work full-time, part-time, or on a temporary basis. However, key questions of “what, when, where, and how” those employers must report will remain unanswered for some time yet.
The Pay Reporting Ordinance gives the City a full year to designate an agency to administer the law after it takes effect. Once designated, that agency would then have another year to create and publish a standardized data reporting form for employers to use to submit their pay data.
No later than one year after this standardized form is published (and it may be in a digital format online), private employers in New York City with 200 or more employees covered employers would be required to provide pay data reports to the designated agency, along with a signed statement certifying data accuracy. Employers would be able to submit reports anonymously, provided they identify themselves in the accompanying certification. Covered employers would be required to provide these reports annually after making their first report.
The Pay Reporting Ordinance would require that employers provide compensation and demographic information on employees as was required by the EEOC’s EEO-1 Component 2 reports in 2017 and 2018 (for background about Component 2 reports, see here). The Component 2 reports included 12 categories of employee data, including pay, corresponding job titles, sex, race, and ethnicity. The designated agency would be permitted to modify this reporting system if it chooses, but it may not require employers to personally identify an employee to the designated agency.
The designated agency would provide covered employers that fail to comply with the Pay Reporting Ordinance’s requirements with a written warning for their first violation. Employers that do not remedy their noncompliance within 30 days would face a $1,000 civil penalty. Subsequent violations would garner a $5,000 penalty without the same prior warning or opportunity to cure. The designated agency would also publish an annual list on its website that includes the name of employers who violated the Pay Reporting Ordinance. However, if an employer remedies its first violation within the 30-day grace period, it will only receive a written warning and will not be included on the annual list.
If enacted, the law would take immediate effect, kickstarting the timeline to designate the relevant City agency.
What the Data Will Be Used for
The second bill (Int. No. 0984-2024) would require the designated agency to compile the data from pay reports submitted pursuant to the Pay Reporting Ordinance and study whether there are disparities in compensation based on gender, race, or ethnicity. These studies would begin one year after the first reports are filed and continue annually afterward.
Should the designated agency find any disparities, it would be required to identify the industries in which the disparities exist and present its findings to the Mayor and City Council within six months, along with recommendations for employers on how to remedy the disparities. These recommendations would be made public.
The bill would also require the designated agency to publish data from the pay reports in aggregate form, in a manner that does not identify specific employers or employees.
What NYC Employers Should Prepare For
The issue of pay data reporting to state and (now) local governments toward a better understanding of pay equity issues is part of an ongoing trend. With Mayor Adams’ deadline to act on these bills fast approaching, and with the bills passing the City Council with a veto-proof majority, employers with 200 or more New York City employees should anticipate new reporting obligations to come due within 24 months.
Covered employers should be on the lookout for release of a standardized reporting form, publication of which will start the one-year clock for the employer’s first report. Additionally, covered employers should ensure that they are adequately organized and prepared to provide the necessary information in their reports to ensure compliance under this new legislation.
*Adam Loch, a Law Clerk – Admission Pending in Epstein Becker Green’s New York office, contributed to the preparation of this article.
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