New York City has passed new legislation requiring certain employers to report employee compensation data, broken down by race/ethnicity and gender. This move signals a continued shift toward greater pay transparency in the U.S. and adds to a growing list of jurisdictions introducing mandatory pay reporting requirements.
Following a City Council vote to override former Mayor Eric Adams' veto, two bills—Int. 982-A and Int. 984-A—were enacted, establishing the framework for annual pay data reporting and city-led pay equity studies.
Although implementation timelines are still being finalized, employers operating in New York City should begin preparing now.
Who will be affected?
The new reporting requirements will apply to non-governmental employers with 200 or more employees working in New York City, including full-time, part-time, and temporary employees.
A New York City agency, yet to be designated, will be appointed by December 4, 2026 to oversee implementation and enforcement of the new laws.
Int. 982-A: Pay data reporting requirements
Under Int. 982-A, the designated city agency will be required to develop and publish a standardized, fillable pay reporting form within one year of its designation. As a result, employers could be required to begin reporting as early as 2027, depending on the pace of implementation.
What data will employers need to report?
The reporting framework is expected to closely mirror the EEOC's former EEO-1 Component 2 reports, which required employers to disclose:
Employee wages
Total hours worked
Data categorized by race/ethnicity and gender
Information grouped into 12 pay bands
The city agency will have discretion to modify reporting categories, including potentially expanding gender identity classifications beyond prior federal standards.
Importantly:
No individual employee data will be submitted
Employers may include contextual explanations with their reports
Employers may submit reports anonymously, though a separate signed certification identifying the employer will still be required
Enforcement and penalties
Each year, the designated agency will publish a list of employers that fail to comply with their reporting obligations.
Before publication, employers will receive:
Written notice of noncompliance
A 30-day cure period to submit missing information
Penalties for failure to comply include:
USD 1,000 for a first offense
USD 5,000 for subsequent offenses
Int. 984-A: City-led pay equity studies
Int. 984-A complements the reporting requirements by mandating annual pay equity studies conducted by the city.
Within one year of receiving employer data, the designated agency must analyze aggregated pay data to:
Identify compensation disparities based on race/ethnicity and gender
Highlight industries where disparities are most prevalent
Examine trends in occupational segregation
The findings will be delivered to the Mayor and City Council and will be made publicly available. While individual employers will not be identified, the reports will include:
Statistical methodologies used
Key findings and trends
Policy recommendations and suggested action plans
How New York City compares globally
With these new laws, New York City becomes the fourth U.S. jurisdiction, after California, Illinois, and Massachusetts, to mandate demographic-based pay reporting.
Globally, however, pay transparency requirements are becoming even more expansive. For example:
The United Kingdom and Australia already require annual gender pay gap reporting for certain employers, with public disclosure
The EU Pay Transparency Directive will require covered employers to report gender pay gap data and conduct joint pay assessments with employee representatives by June 2026.
This broader trend suggests that pay data reporting is increasingly becoming a standard compliance requirement for multinational employers.
What employers should do now
Although the laws are now in effect, reporting timelines will depend on when the city designates the responsible agency and issues formal guidance.
In the meantime, employers can prepare by:
Reviewing current pay structures and job classifications
Auditing data collection and HR systems for accuracy and consistency
Assessing internal pay equity risks before reporting becomes mandatory
Aligning U.S. reporting processes with global pay transparency obligations, where applicable
How Atlas HXM Can Support
Depending on implementation timelines, New York City employers could be required to submit pay data as early as 2027 . As regulatory scrutiny around pay equity continues to grow in the U.S. and globally, early preparation will be key to mitigating risk and ensuring compliance.
Atlas HXM continues to monitor developments in pay transparency and workforce compliance worldwide. If you'd like to understand how these new requirements may impact your organization or how to streamline pay data reporting across jurisdictions, our team is here to help.