On Dec 4, 2025, the New York City Council overrode Mayor Eric Adams’ vetoes and enacted a two-bill pay equity package sponsored by Majority Leader Amanda Farías and Council Member Tiffany Cabán. These new NYC pay equity reporting laws require large private employers to file annual pay data reports and authorize the City to conduct an annual pay equity study. These rules will create new compliance duties for covered employers. Human resources professionals should understand the basic requirements now and be ready to adapt when the reporting system is in place.
Background – Pay Equity in New York
New York has taken several steps toward pay equity in recent years. In 2019, the state expanded the New York Equal Pay Act to cover a wide range of protected characteristics and lowered the threshold from equal work to “substantially similar work”. That same year, a salary history ban prohibited employers from asking applicants about prior compensation and from relying on salary history in setting pay. More recently, New York enacted a statewide pay transparency law requiring employers with at least four employees to include compensation ranges and job descriptions in advertisements. Employers should also be familiar with New York City’s 2022 salary‑disclosure ordinance.
For deeper background on these existing pay‑equity measures, see our earlier posts:
The NYC pay equity reporting laws build on these earlier measures. They shift responsibility for uncovering pay disparities from individual workers to employers and the City. As Majority Leader Amanda Farías explained when the package was introduced, “[b]y requiring employers to report pay data [and] mandating an annual citywide pay equity study . . . we are ensuring that transparency leads to action. . . .”
Pay Data Reporting (Introduction 982‑A / Local Law 173 of 2025)
Who is covered?
Private employers with 200 or more employees working in New York City. The headcount includes full‑time, part‑time, and temporary workers. Coverage depends on the highest number of employees employed at any time during the reporting year. Government agencies are not subject to the law.
What must be reported?
Covered employers must compile an annual pay report using the Equal Employment Opportunity Commission’s EEO‑1 Component 2 categories. That means grouping employees by job category, pay band, gender, and race/ethnicity. Employers may include explanatory remarks.
A company officer must sign a statement attesting that the report is complete and accurate.
How will reporting work?
| Milestone | Requirements | Expected timing* |
|---|---|---|
| Agency Designation | The Mayor must select a City agency (likely the Department of Consumer and Worker Protection) to administer the program. | Within 1 year of Dec. 4, 2025 |
| Form Development | The designated agency must build a standardized, electronic, fillable reporting form. | Within 2 years |
| First Employer Reports Due | Employers file their first pay reports using the standardized form. | Within ~3 years |
| Annual Reporting | After the first report, covered employers must file annually. | Ongoing |
*Actual dates will depend on when the Mayor designates the agency and when the agency publishes the reporting form; the statute contemplates a four‑and‑a‑half‑year rollout.
Enforcement and Penalties
Employers that fail to submit accurate data face a tiered enforcement scheme. The law provides for warnings for first‑time violations if cured within 30 days and civil penalties of $1,000 for a first offense and $5,000 for subsequent offenses. Importantly, the agency must publish a list of non‑compliant employers on its website.
Annual Pay Equity Study (Introduction 984‑A / Local Law 174 of 2025)
What does the study require?
Under the companion law, the designated agency—in collaboration with the Commission on Gender Equity and other city agencies—must conduct an annual pay equity study using the data submitted by employers. Key points include:
Timing: The first study must be completed within one year after employers submit their initial reports and every year thereafter.
Scope: Analysts must evaluate whether compensation disparities exist based on gender, race, and ethnicity, and identify industries where inequities are most pronounced.
Publication: Within six months of completing each study, the agency must submit a report to the Mayor and the Speaker of the City Council, and publish aggregated findings on a public website, ensuring that individual employee identities are protected.
Why does this matter?
The study closes the loop created by the reporting law. Employers supply data; the City analyzes and publishes trends; and policymakers and businesses gain insights into occupational segregation and wage gaps. According to Council Member Tiffany Cabán, “requiring large employers to report pay data and mandating rigorous, public analysis . . . give[s] policymakers the information needed to close wage gaps at their root.”
Practical Implications of NYC Pay Equity Reporting for Employers
The NYC pay equity reporting package does not require the immediate filing of pay reports. However, employers with operations in New York City should begin preparing now. Consider the following steps:
Assess coverage. Determine whether your organization employed 200 or more workers in New York City during any point in the last year. Remember to count part‑time and temporary employees.
Organize data by EEO‑1 categories. Review current HR and payroll systems to ensure you can pull compensation data broken down by job category, pay band, race, ethnicity, and gender. This is also a good time to review job descriptions and ensure they are up to date.
Audit pay practices. Conduct an internal pay equity analysis to identify and address disparities before submitting reports. Our earlier posts on the Equal Pay Act and salary history ban provide useful context.
Monitor rulemaking. The designated agency will publish regulations and a standardized reporting form. Stay informed by following official announcements, and consult counsel when the NYC pay equity reporting rules are released.
Integrate with existing disclosure requirements. Employers already subject to New York City and New York State pay transparency laws must disclose salary ranges in job postings. Aligning these disclosures with the data you will report can minimize inconsistencies.
Looking Ahead
The Farías–Cabán pay equity package reflects growing momentum to address perceived wage gaps through transparency and accountability. The Council’s passage of these NYC pay equity reporting bills over a mayoral veto underscores its focus on pay equity. Because the requirements will not take effect for several years, employers have time to prepare, but proactive planning is essential. We will continue to monitor rulemaking and provide updates as the City develops the reporting system and publishes study results.
For more employment law updates, sign up for the Horton Law email newsletter and follow us on LinkedIn.
