Attention, NYC Employers: NYC Poised To Enact Pay Equity Reporting Requirements

On October 9, 2025, the New York City Council passed two bills, 982-A and 984-A, which together would require (i) private employers with more than 200 employees working in New York City to submit a pay data report to an agency designated by the mayor and (ii) a designated agency to conduct an annual pay equity study.

Council Member Tiffany Cabán, who sponsored bill 982-A, explained that the goal is to create accountability and equity and to identify and correct disparities in compensation based on gender, race, and ethnicity. These bills are on Mayor Eric Adams' desk, and he has 30 days to sign them, veto them, or do nothing, which would result in their automatic enactment.

Bill 982-A directs the mayor to designate a city agency within one year of the effective date to conduct a pay equity study of the private sector workforce. This agency will establish a system to collect pay reports from employers with 200 or more employees in New York City. The designated agency will develop a standardized fillable form, which may be electronic or web-based. Reporting employers will have the option to submit the form anonymously, but all employers must submit the statement of accuracy described below. Employers will have one year to submit their first report and thereafter will be required to file reports annually.

The pay reports will include wage information and total hours worked by employees broken down by race, ethnicity, sex, and job category. However, the designated agency may adopt changes, including adding reporting based on gender identities. Employers will have the option to provide explanatory remarks regarding any information contained in the report. Importantly, the report will not require the employer to provide an individual employee's personal information.

Each employer will be required to separately submit a signed statement confirming the submission of its pay report and a statement of accuracy, which confirms the accuracy of the submitted information. Employers that fail to do so may be subject to civil penalties and be publicly listed on the agency's website. For the first offense, employers will be given a written warning and a 30-day cure period.

Bill 984-A requires the designated agency, in coordination with the Commission on Gender Equity and other relevant agencies, to conduct an annual pay equity study on private employers employing 200 or more employees. This agency will analyze the data to determine whether there are pay disparities based on gender, race, or ethnicity, as well as trends in occupational segregation based on gender, race, or ethnicity. The agency will also identify any actions employers should take to address disparities. This agency will make public recommendations and will publish aggregated data from these pay reports, ensuring that no specific employer's or employee's identifying information is disclosed.

If they become law, Bills 982-A and 984-A take effect immediately.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.