{"id":73610,"date":"2025-12-17T18:42:08","date_gmt":"2025-12-17T18:42:08","guid":{"rendered":"https:\/\/www.newsbeep.com\/us-ny\/73610\/"},"modified":"2025-12-17T18:42:08","modified_gmt":"2025-12-17T18:42:08","slug":"mayoral-override-nyc-employers-to-face-new-pay-data-reporting-obligations-employee-rights-labour-relations","status":"publish","type":"post","link":"https:\/\/www.newsbeep.com\/us-ny\/73610\/","title":{"rendered":"Mayoral Override: NYC Employers To Face New Pay Data Reporting Obligations – Employee Rights\/ Labour Relations"},"content":{"rendered":"

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\nOgletree Deakins is a labor and employment law firm representing management in all types of employment-related legal matters. Ogletree Deakins has more than 850 attorneys located in 53 offices across the United States and in Europe, Canada, and Mexico. The firm represents a range of clients, from small businesses to Fortune 50 companies. <\/p>\n

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\n On December 4, 2025, the New York City Council overrode a mayoral veto to enact two new pay data reporting laws, Int. 0982-2024-A and Int. 0984-2024-A… \n <\/p>\n


\n United States
\n New York
\n Employment and HR \n <\/p>\n


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On December 4, 2025, the New York City Council overrode a
\nmayoral veto to enact two new pay data reporting laws,\u00a0Int. 0982-2024-A<\/a>\u00a0and\u00a0Int. 0984-2024-A<\/a>, that will require large
\nemployers to submit annual reports with pay data by race,
\nethnicity, and sex, modeled after the former federal EEO-1
\nComponent 2 reports, and provide for the city to perform annual pay
\nequity audits based on the information submitted.<\/p>\n

Quick Hits<\/p>\n


\nThe New York City Council enacted two new pay data reporting
\nlaws, requiring large employers to submit annual reports detailing
\npay data by race, ethnicity, and sex.
\n
\nThe designated agency will collect demographic information
\nmodeled after the former federal EEO-1 Component 2 reports and will
\nhave the authority to modify reporting requirements, including
\noptions for different gender identities.
\n
\nEmployers face penalties for noncompliance, including written
\nwarnings and fines, and the designated agency will conduct annual
\npay equity audits to evaluate potential pay disparities. <\/p>\n

The City Council had\u00a0initially passed the measures<\/a>\u00a0in October
\n2025, but outgoing Mayor Eric Adams vetoed the legislation on
\nNovember 7, 2025. The city council then voted to override those
\nvetoes, setting in motion the establishment of a pay data reporting
\nscheme for the city’s largest employers.<\/p>\n

Pay Data Reporting<\/p>\n

Int. 0982-2024-A will require private employers with more than
\n200 employees working in New York City to submit pay data reports
\nto a soon-to-be-designated city agency. The reports would include
\ndemographic and occupational information and be submitted annually
\nusing an electronic form.<\/p>\n

Designated Agency<\/p>\n

Int. 0982-2024-A establishes a new pay data reporting system. By
\nDecember 4, 2026, the mayor will designate an agency to
\n\u201cconduct a pay equity study of the private workforce\u201d
\nand set up a system to collect information from covered employers.
\nWithin a year after the designation, the agency will \u201cdevelop
\na standardized fillable form, which may be electronic or
\nweb-based,\u201d to allow covered employers to submit the pay data
\nreports anonymously. Employers will then be required to submit the
\nreports within a year after the publication of the standardized
\nforms and do so annually thereafter.<\/p>\n

Reporting Requirements<\/p>\n

The pay data reports will collect current demographic
\ninformation of employees, modeled after the former federal\u00a0EEO-1 Component 2 reports<\/a>, which were collected
\nby the U.S. Equal Employment Opportunity Commission (EEOC) in 2019
\nfor the years 2017 and 2018. Those Component 2 reports required
\nemployers to place employees in one of twelve pay bands within
\ntheir respective EEO-1 job category and separate them by gender and
\nrace or ethnicity. Those reports allowed employers to rely on the
\ntotal taxable wages for federal income tax purposes, as reported in
\nBox 1 of the W-2 tax forms for each employee.<\/p>\n

The New York City law would allow the designated agency to make
\npotential modifications to the reports, \u201cincluding but not
\nlimited to inclusion of reporting options accounting for different
\ngender identities.\u201d The reports must also allow covered
\nemployers \u201cto provide explanatory remarks regarding any of
\nthe information contained in the report.\u201d<\/p>\n

Statement of Accuracy<\/p>\n

Employers will additionally be required to submit a
\n\u201csigned statement by an authorized agent\u201d confirming
\nthe submission of the report and attesting to the accuracy of the
\ninformation submitted.<\/p>\n

Penalties<\/p>\n

Covered employers that fail to submit the pay data reports will
\nface a written warning and be provided thirty days to comply.
\nFailure to comply within thirty days could result in a civil
\npenalty of $1,000. Subsequent violations will be subject to a civil
\npenalty of $5,000.<\/p>\n

Annual Pay Equity Audits<\/p>\n

Int 0984-2024-A provides that the designated agency will use the
\ninformation from the reports to conduct a study that evaluates
\nwhether there are potential pay disparities based on gender and
\nrace or ethnicity and deliver the findings within six months to the
\nmayor and the speaker of the city council within one year after
\nemployers are required to submit their reports.<\/p>\n

The designated agency will be required to publish the aggregate
\ninformation from the reports submitted by the covered employers in
\na way that does not identify any particular covered employer or
\ncovered employer’s employees.<\/p>\n

Next Steps<\/p>\n

With the new pay data reporting laws, New York City joins other
\njurisdictions, such as\u00a0California<\/a>,\u00a0Illinois<\/a>, and\u00a0Massachusetts<\/a>, in the trend of establishing pay
\ndata reporting requirements aimed at reducing pay disparities and
\nensuring equal employment opportunities. It is anticipated that
\nstates and local municipalities will continue to impose their own
\nreporting obligations, as the federal government has shifted its
\nfocus away from such reporting.<\/p>\n

The content of this article is intended to provide a general
\nguide to the subject matter. Specialist advice should be sought
\nabout your specific circumstances.<\/p>\n

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