The New York City Council overrode Mayor Eric Adams’ veto and approved two new laws, Int. 982-A and Int. 984-A. These measures aim to increase wage transparency and address pay disparities based on race and gender. They require large private employers to report pay data and authorize the City to conduct annual pay equity studies.
The first law, Int. 982-A, sets annual pay reporting requirements for private employers with 200 or more employees in New York City. Reports must include wage and hours worked information by race, ethnicity, and gender across 12 pay bands, following the structure of the former federal EEO-1 Component 2 framework. Employers can submit data anonymously but must also provide a signed certification confirming accuracy. Those who fail to comply may face fines of $1,000 for the first violation and $5,000 for subsequent violations, and their names may be published after a 30-day grace period.
The second law, Int. 984-A, focuses on pay equity analysis. It directs a designated city agency, working with the Commission on Gender Equity, to use aggregated employer data to conduct annual studies on compensation disparities. These studies will lead to recommendations for employer action plans, while individual employer data will remain confidential.
The legislation takes effect immediately, but reporting deadlines depend on future steps. The Mayor must appoint an implementing agency by December 2026, and that agency will have up to 12 months to create the reporting format. Employers will then have one year to submit their first report. While timelines could extend to 2028, reporting may start as early as 2026. Employers should begin preparing now by reviewing pay structures and data collection systems to ensure compliance.