Overview
- The new laws require private employers with 200 or more New York City workers to file annual pay reports showing employee counts by race or ethnicity and gender across job categories and pay bands.
- The framework is modeled on the EEOC’s former EEO-1 Component 2 approach, which could entail reporting W-2 wages and total hours worked by demographic group within specified pay bands.
- Employers may submit data anonymously but must also file a separate signed statement identifying the company and certifying the accuracy of the submission.
- The rollout follows a phased schedule: up to 12 months for the mayor to designate an agency, up to 12 months for that agency to build the system, then up to 12 months for employers to submit their first reports.
- Noncompliance can trigger a $1,000 first fine after a 30-day cure window and $5,000 for later violations, with the city authorized to publish a list of employers that fail to comply, and an annual aggregated pay equity study will be conducted with the Commission on Gender Equity.