Large New York City employers may soon be required to submit a report to regulators detailing their workforce demographics and pay data. Specifically, on October 9, 2025, the New York City Council approved two bills of legislation that would create a framework for annual pay data reporting by larger private-sector employers and mandate an ongoing, city-led analysis of that data to identify disparities by gender and race or ethnicity. Both bills would take effect on the same date, effectively binding  the two measures into a single policy framework. 

Annual pay reporting

The reporting legislation, Int. No. 982-A, establishes who must report, what must be reported, and how compliance will be enforced. It would require New York City employers with at least 200 employees to report employees’ titles, pay information, and certain demographic information. All workers—full-time, part-time, and temporary—are counted for the 200-employee threshold necessary to trigger reporting obligations. Where headcount fluctuates, the threshold is measured by the highest number of employees concurrently employed at any point during the reporting year. 

Int. No. 982-A further requires the Mayor to assign a “designated agency” to collect employer reports. Within one year of designation, that agency must publish a standardized, configurable, and fillable reporting form so all required fields can be completed before submission. The form would, as noted above, require employees’ salaries and rates of pay for employees, broken down by job title, sex, and race/ethnicity. No later than one year after the form is published, and annually thereafter, covered employers must submit a pay report along with a signed statement by an authorized representative confirming the accuracy of the information contained in the report.

If an employer fails to accurately report the required data, it could face civil penalties. A first offense is subject to a written warning if cured within 30 days  after service of a summons, or a $1,000 penalty if not cured within that period. Each subsequent offense carries a $5,000 penalty. 

Annual pay equity study

Int. No. 982-A’s companion study legislation, Int. No. 984-A, requires the designated agency assigned by the Mayor, in collaboration with relevant city agencies, to conduct an annual pay equity study. The first study must occur no later than one year after covered employers submit their initial pay reports in accordance with Int. No. 982-A, and annually thereafter. The study must evaluate whether compensation disparities exist among employees based on gender and race or ethnicity, and identify industries where disparities may be prevalent.

Within six months after each study, the designated agency must deliver its findings to the Mayor and the Speaker of the City Council. The designated agency must also publish the data contained in employer pay reports and any underlying datasets, subject to applicable confidentiality protections.

Conclusion

Given the Council's overwhelming approval, these two bills are likely to become law in New York City. As a result, now is a prudent time for large New York City employers to audit their practices to ensure that they are in compliance with state, local, and federal law. When these reviews are conducted, especially with legal assistance, they will help businesses identify and address potential pay concerns before the data is sent to government agencies for analysis.