Client Alert: NYC Pay Data Reporting and Pay Data Analysis Laws Take Effect
Date: January 13, 2026
By:
Lisa M. Brauner
What’s Required
Under the pay data reporting law (Int. 982-A), covered private-sector employers (those with more than 200 employees working in New York City) must submit annual pay data reports to a City agency designated by the Mayor. The law sets a sequence of implementation steps:
- Agency designation and study mandate. Within one year of the law’s effective date, the Mayor must designate a City agency to conduct a pay equity study of the private-sector workforce and establish a system to collect information from covered employers.
- Standardized form. Within one year after the designation, the designated agency must develop and publish a standardized, fillable reporting form (electronic or web-based).
- Employer reporting. Beginning no later than one year after the standardized form is published, covered employers must file pay data reports annually on the schedule set by the designated agency.
(a) Reporting Structure. The report must place employees into EEO-1 job categories and pay bands, disaggregated by gender and race/ethnicity, and include hours worked. The law is modeled on the now-defunct U.S. Equal Employment Opportunity Commission’s EEO-1 Component 2 form requirements from 2017-2018 (W-2-based compensation grouped in pay bands by job category and demographic category), with details to be finalized by the City’s standardized form and rules. The law authorizes the agency to adopt modifications like gender identity reporting options
(b) Certification. Covered employers submit a separate signed certification of accuracy by an authorized agent to the designated city agency (although employers may submit the completed form anonymously); and
(c) Publication. The agency must publish a list of employers that fail to comply after notice and a 30-day cure window.
Under the pay data analysis law (Int. 0984-A):
- Citywide pay equity study. Within one year after the first collection of employer pay data and annually thereafter, the designated agency, in collaboration with the Commission on Gender Equity and other relevant agencies, must conduct a pay equity study assessing compensation disparities by gender and race/ethnicity, and assessing industries where disparities may be prevalent and occupational segregation trends.
- Reporting and publication. Within six months after each annual study is conducted, the agency must provide a report on the study’s findings to the Mayor and the Speaker of the City Council and publish aggregate results that are not identifiable to any employer or employee.
Time for Compliance
Employer filing obligations do not begin immediately. The compliance clock runs as follows:
- Effective date. The laws took effect on December 4, 2025.
- Agency designation. The Mayor has up to one year from the effective date to designate the implementing agency.
- Standardized form. Within one year after designation, the agency must develop and publish the standardized reporting form.
- First reports due. No later than one year after the form is published, covered employers must submit their first annual pay data report on the schedule the agency sets by rule. The agency will specify the filing due date, reporting reference period (e.g., prior calendar year), filing mechanics and any rules for reporting, extensions and corrections.
Under Int. 982-A, employer noncompliance triggers escalating consequences:
- Initial notice and cure. A written warning and 30 days to cure for a first offense.
- Civil Penalties. If an employer fails to comply within 30 days of a summons, they shall be subject to a civil penalty of $1,000, and $5,000 as a civil penalty for subsequent offenses. Covered employers’ Human Resources and in-house legal teams would be well-advised to confirm whether the New York City 200-employee threshold will be met, align job architecture with EEO-1 categories, validate wages and hours, and prepare governance for the new statement-of-accuracy requirement—positioning the organization to comply quickly once the agency and reporting form are announced.
The information contained here is not intended to provide legal advice or opinion and should not be acted upon without consulting an attorney. Counsel should not be selected based on advertising materials, and we recommend that you conduct further investigation when seeking legal representation.