New York, NY: New Pay Data and Pay Equity Reporting Requirements

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All Employers with Employees in New York, NY

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Quick Look

  • On October 9, 2025, the New York City Council passed a bill that would require employers with 200 or more employees to submit pay data reporting and a bill to require the City to conduct pay equity analysis of these reports.
  • No. 0982-2024 will require covered employers to submit pay data reporting corresponding with the categories of information required by the Equal Employment Opportunity Commission’s EEO-1 Component 2 reporting for years 2017 and 2018 including reporting options accounting for different gender identities.
  • Int. No. 0984-2024 will require a designated agency to conduct a pay equity study with the New York City Commission on Gender Equity within one year after the pay data reports are submitted.

Discussion

On October 9, 2025, the New York City Council passed a bill that would require employers with 200 or more employees to submit pay data reporting and a bill to require the city to conduct pay equity analysis of these reports. The two bills are currently pending Mayor Eric Adams’ signature.

 

Pay Data Reporting

 

Int. No. 0982-2024 will require covered employers to submit pay data reporting corresponding with the categories of information required by the Equal Employment Opportunity Commission’s EEO-1 Component 2 reporting for years 2017 and 2018 including reporting options accounting for different gender identities. Specifically, this would require reporting of salaries and pay rates broken down by employees’ job titles, sex, and race/ethnicity. A signed statement of accuracy must accompany the information. Violators will be assessed with a civil penalty of up to $5,000. The date of when the reporting requirement begins is not yet known since the Mayor must designate an agency to conduct a pay equity study and create a standard form for submissions.

 

Pay Equity Study

 

Int. No. 0984-2024 will require the agency designated above to conduct a pay equity study with the New York City Commission on Gender Equity within one year after the pay data reports are submitted. The purpose of the study is to evaluate and examine disparities based on gender, race, or ethnicity and identify industries that are affected by disparities.

 

Action Items

  1. Continue monitoring legislation for updates.
  2. Review and update job descriptions and pay data for compliance.

 

Disclaimer: This document is designed to provide general information and guidance concerning employment-related issues. It is presented with the understanding that ManagEase is not engaged in rendering any legal opinions. If a legal opinion is needed, please contact the services of your own legal adviser. © 2025 ManagEase