New York City: Pay data reporting requirements enacted

At a glance

• Effective December 4, 2025, New York City enacted pay data reporting requirements.
• The law passed over the Mayor’s objections and adds new employer obligations.
• Employers must submit pay data reports to ensure compliance with wage transparency standards.
• The measure aims to address pay equity and strengthen enforcement of anti-discrimination laws.

Effective December 4, 2025, New York City enacted pay data reporting requirements over the Mayor’s veto. Under Int. 982-A, private employers with at least 200 employees working in the City must submit a pay data report annually to a designated agency. Under Int. 984-A, the designated agency will use submitted pay data information to evaluate whether there are disparities in compensation based on gender, race, or ethnicity and submit a report with findings.

While the legislation took effect immediately, various actions are required before employers must file reports. The mayor must designate a responsible agency by December 4, 2026. The agency then has up to one year to create a standardized form and system to collect the required information. No later than one year after the agency publishes the form, employers must submit the pay report.

Employers are encouraged to monitor for further developments, including forms, submission procedures, and enforcement guidance.