On October 16, 2025, the New York City Council passed two bills that, if enacted, will require large employers to report detailed pay data by race and gender. These measures aim to enhance pay equity transparency across the city’s workforce. While the reporting obligations would take effect immediately, employers will not be required to submit data until the City establishes the process for doing so. In this article, we describe the proposed laws.
Overview of the Reporting Framework
Under Bill Int. 982A, the City must designate a responsible agency within one year of the law’s effective date. Once designated, that agency will have another year to develop a standardized, fillable reporting form for covered employers.
Within one year of that form’s publication—and annually thereafter—employers with 200 or more employees (including full-time, part-time, and temporary workers) will be required to submit pay data reports. These reports must include information aligned with the categories used in the EEOC’s EEO-1 Component 2 reporting for 2017–2018, including employee race, ethnicity, and gender.
The designated agency may also update or expand these categories, such as by adding reporting options that reflect different gender identities.
Employer Certification and Compliance
In addition to filing the pay report, each employer must submit a signed certification statement confirming the accuracy and completion of its submission. While employers may choose to file their pay reports anonymously, the certification statement itself must identify the employer.
The designated agency will publish an annual list of noncompliant employers on its website. Before appearing on that list, employers will receive written notice and at least 30 days to cure any deficiencies.
Violations will carry the following penalties:
- First offense: A written warning if corrected within 30 days of notice; otherwise, a $1,000 civil penalty.
- Subsequent offenses: A $5,000 civil penalty per violation.
Citywide Pay Equity Study
Under the companion measure, Bill Int. 984A, the designated agency must conduct an annual pay equity study beginning one year after the first round of employer submissions. The study will analyze pay data in aggregate form and publish results that do not identify specific employers or employees.
The agency will also continue to post a list of employers that fail to comply with the reporting requirements.
Legislative Outlook
Both bills passed with strong support—over 80% of the City Council—enough to override a potential veto by Mayor Eric Adams. If enacted, these measures will establish one of the most comprehensive local pay transparency reporting systems in the country.
What Employers Should Do Now
Employers with 200 or more employees should begin reviewing internal pay data systems and ensuring that demographic and compensation information is accurately maintained. Preparing early will make compliance easier once the reporting process is finalized.
Forework Can HelpIf you have questions about these new pay data reporting bills or how to prepare your organization for compliance, contact Forework for assistance.