New York City has enacted two significant pay data reporting laws that will require large private employers to submit detailed annual compensation information to the City. The new measures reflect a broader local and national push toward pay equity and are designed to identify compensation disparities based on gender, race, and ethnicity.
The laws apply to private employers with 200 or more employees working in New York City, including full-time, part-time, and temporary workers. Government employers and smaller private employers are excluded.
Int. 982-A: Pay Data Reporting Requirements
Under Int. 982-A, covered employers will be required to submit annual pay data reports to a city agency designated by the Mayor. The Mayor must designate the responsible agency by December 4, 2026, and the agency will then have up to one year to develop a standardized reporting form. Employers will be required to begin submitting reports one year after the form is published, meaning that reporting obligations could begin as late as 2028, depending on implementation timelines.
The reporting form will be modeled on the EEOC’s former EEO-1 Component 2 framework and will require employers to report wages and total hours worked by race, ethnicity, and gender across 12 pay bands. An authorized employer representative must also submit a signed certification attesting to the accuracy of the reported information.
The law includes enforcement mechanisms designed to encourage compliance rather than immediate penalties. Each year, the designated agency will publish a list of employers that fail to comply with the reporting and certification requirements. However, employers will receive notice of noncompliance and a 30-day cure period before being publicly identified.
If the issue is corrected within the cure period, employers will receive a written warning for a first violation. If not timely cured, the first offense carries a $1,000 civil penalty, with a $5,000 penalty for each subsequent violation.
Int. 984-A: Pay Equity Study and Public Reporting
The second law, Int. 984-A, requires the City to analyze the collected pay data. One year after employers begin submitting pay reports, the designated agency, working in collaboration with the Commission on Gender Equity and other relevant agencies, must conduct an annual pay equity study.
The study will evaluate whether compensation disparities exist based on gender, race, or ethnicity; identify industries where disparities may be prevalent; and assess trends in occupational segregation. Within six months of completing each study, the City must publish a report summarizing its findings, including the statistical methodologies used and recommendations for employer action plans.
While the City will publicly release aggregated pay data and recommendations, the law expressly prohibits disclosure of employer-specific or employee-specific identifying information.
Takeaways
These laws underscore the growing focus on pay equity and the importance of maintaining reliable, well‑organized compensation and demographic data. They highlight the need for clear internal processes that support accurate reporting and careful handling of sensitive information as the City begins collecting pay data and analyzing trends across job categories in accordance with these new laws.
This summary is for informational purposes only and is not intended to constitute legal advice. This information should not be reused without permission.