New York City’s pay transparency laws have already reshaped how employers advertise compensation. Now, the City Council is aiming higher. With the passage of two bills, Int. 0982-A and Int. 0984-A, New York City could become one of the first local governments to implement annual pay data reporting modeled after the federal EEO-1 Component 2 framework.
If signed by Mayor Eric Adams, the measures would require private employers with 200 or more New York City employees to submit demographic and pay data annually and empower the city to conduct recurring pay equity studies. Together, the bills represent a shift toward transparency that moves beyond job postings and into the realm of aggregate compensation reporting, analysis, and public accountability.
Where the Law Stands Today
New York State already requires employers to disclose compensation in job postings, and the City has its own pay transparency law under NYC Administrative Code § 8-107(32). Both rules focus on upfront transparency in hiring, requiring salary ranges and clear language around compensation for open roles.
But neither law demands that employers track or report compensation data by gender or race. Nor do they authorize a public agency to investigate pay disparities across the private sector. These bills aim to close that gap by extending transparency from the front end of the hiring process to the structure of employer pay systems themselves.
What Int. 0982-A Requires
Int. 0982-A would create a new Section 12-208.2 in the New York City Administrative Code, requiring covered employers, those with at least 200 employees working in the city, to submit annual pay data reports to a designated agency.
The Reporting Framework
The report must include demographic and occupational compensation data similar to what employers submitted under the federal EEO-1 Component 2 data collection in 2017 and 2018. That federal effort required employers to categorize employees by job type and report total compensation (based on Box 1 of the W-2) and total hours worked, disaggregated by gender, race, and ethnicity.
New York City’s version would follow this same structure, but the designated agency may adapt it to include additional gender identity fields or other enhancements. A standardized electronic form will be published by the designated agency. Employers may choose to submit anonymously, although they still must sign a separate statement attesting to the accuracy of their data.
Importantly, the legislation clarifies that no individual employee’s personal information will be disclosed in the reports. However, employers must still disclose compensation by demographic category as required by the bill.
Implementation Timeline
If adopted, the law would roll out in three phases:
- Within one year of the law’s effective date, the Mayor must designate a city agency to oversee implementation.
- Within one year after the agency’s designation, that agency must create and publish a standardized electronic reporting form.
- Within one year after the form’s publication, covered employers must begin filing annual reports.
The current version of the bill reflects a scaled-back compromise. Lawmakers narrowed its scope in 2024 to apply only to large employers and streamlined the reporting format. That compromise helped the legislation pass with more than 80% Council support, enough to override a mayoral veto.
Penalties and Publication
To facilitate compliance, the bill imposes penalties. An employer that fails to submit the required report and signed attestation may receive a written warning or face a $1,000 fine for the first offense. Subsequent violations carry a $5,000 penalty. The City will also publish a list of noncompliant employers, but only after a 30-day cure period.
What Int. 0984-A Adds
While Int. 0982-A establishes the framework for pay data collection, Int. 0984-A explains how the City plans to use that data.
The bill requires the designated agency, likely working with the Commission on Gender Equity, to conduct an annual pay equity study. This analysis must evaluate whether compensation disparities exist across gender and racial lines and identify any patterns of occupational segregation.
Within six months of completing each study, the agency must submit findings to the Mayor and the City Council Speaker. The published report will include a summary of pay disparities, the statistical methods used, and recommendations for employer action plans to address any issues identified.
The City will also publish aggregate data from the pay reports in a way that preserves individual and employer anonymity. However, employers should expect these publications to shine a spotlight on industry-specific trends, potential inequities, and public expectations for remediation.
Compliance and Risk Considerations
For multistate employers, especially those already complying with California’s Pay Data Reporting law and its recent amendment, as well as Illinois’ Equal Pay Registration Certificate program, this structure will look familiar. Like those laws, Int. 0982-A relies on EEO-1 Component 2-style data and demographic reporting. Massachusetts, by contrast, requires submission of an EEO-1 form but does not yet mandate annual pay data analysis.
But in NYC, there are key distinctions:
- Coverage is Localized: The NYC bills apply only to employees working within the five boroughs. Employers must isolate this population for reporting.
- Public Disclosure is Broader: California restricts public access to company-level data. In contrast, New York City will publish aggregate findings and recommend corrective actions.
- Enforcement is Targeted: The law doesn’t penalize pay disparities directly, but it does penalize non-reporting. Reputational risk may follow disclosure.
Employers should begin preparing by evaluating their HRIS and payroll systems, confirming how demographic data is collected, and assessing whether compensation structures align with published salary ranges.
A Broader Trend and a Warning
These bills mark the latest chapter in a growing national movement toward pay equity enforcement through transparency. Rather than policing individual decisions, regulators are leaning on aggregated data to surface disparities that might otherwise go unchallenged.
But with greater transparency comes greater scrutiny. Employers that submit reports under New York City’s new law may find themselves under public pressure to explain or remedy perceived pay gaps, regardless of legal liability. In that sense, compliance may require more than data preparation; it may demand internal pay audits, equitable compensation strategies, and meaningful change.
Parting Thoughts
While Mayor Adams has not yet signed the bills, given the overwhelming Council support, their passage appears imminent. Once signed, the rollout begins: one year for agency designation, another for form development, and another before the first reports are due.
Employers with large footprints in New York City should begin preparing now. Identify whether your employee count meets the 200-worker threshold, review how compensation data is categorized, and consult legal counsel to prepare for the public-facing nature of this new compliance obligation.
Pay transparency is no longer limited to job postings. In New York City, it may soon mean showing your work.