New York City Council Passes Bills for Enhanced Pay Equity Reporting

On October 9, 2025, the New York City Council enacted two significant bills aimed at enhancing pay equity through new reporting obligations for employers. These measures await review from Mayor Eric Adams, who has until November 8, 2025, to either sign or veto the legislation. If enacted, New York City will join California, Illinois, and Massachusetts as a pioneer in mandating pay data reporting amidst recent rollbacks of similar requirements at the federal level by the Equal Employment Opportunity Commission (EEOC).

Details of the New Reporting Obligations

The first bill, known as Int. No. 0982-2024 or the “Pay Reporting Ordinance,” mandates that private employers in New York City with 200 or more employees submit detailed pay information to the city government. This headcount includes all personnel working in the city, irrespective of their employment status—full-time, part-time, or temporary. However, specifics regarding the reporting process, including the timeline and format, will remain unclear for the foreseeable future.

Once the bill takes effect, the city has one year to appoint an agency responsible for overseeing compliance. Following this, the designated agency will have another year to develop a standardized reporting form for employers. Employers will then be required to submit their first pay data report within one year of the form’s release, along with a signed certification of the data’s accuracy. They may choose to remain anonymous when submitting reports, provided they identify themselves in the certification.

The data required will mirror the EEOC’s EEO-1 Component 2 reports from 2017 and 2018, encompassing categories such as pay, job titles, sex, race, and ethnicity. Non-compliance will result in a written warning for first-time offenders. If they fail to rectify the issue within 30 days, a civil penalty of $1,000 will be imposed. Repeat violations will incur a higher penalty of $5,000, with no prior warning.

Implications for Pay Equity Studies

The second bill, identified as Int. No. 0984-2024, requires the designated agency to analyze the data gathered from the pay reports to identify any compensation disparities based on gender, race, or ethnicity. This analysis will commence one year after the initial reports are filed and will continue annually.

If disparities are identified, the agency must specify the industries affected and report its findings to Mayor Adams and the City Council within six months. Recommendations for addressing these disparities will also be made public, ensuring transparency and accountability. Additionally, the agency will publish the aggregated data from the reports in a way that does not identify individual employers or employees.

As the deadline for Mayor Adams to act approaches, employers with 200 or more employees in New York City should prepare for the upcoming reporting obligations. With the City Council passing these bills by a veto-proof majority, the introduction of the standardized reporting form will trigger a timeline for compliance. To avoid penalties, employers should organize their data collection processes to meet the new requirements effectively.

The push for improved pay data reporting reflects a broader trend across various jurisdictions aimed at addressing pay equity issues. If these bills are signed into law, they will mark a significant step forward in promoting transparency and equality in compensation practices within New York City.