Overview
- Private employers with more than 200 workers in New York City must submit annual, race/ethnicity/sex-disaggregated pay and hours data using an electronic form modeled on the EEOC’s former EEO-1 Component 2.
- The rollout is phased: the mayor must name a collecting agency by December 4, 2026, the agency then has one year to publish the form, and employers have up to one year after form publication to file their first reports.
- Data may be submitted anonymously if accompanied by a signed accuracy attestation, a feature Mayor Eric Adams cited in his veto over data reliability and enforcement concerns.
- Noncompliance carries a 30-day cure period before public listing, with civil penalties of $1,000 for a first offense and $5,000 for subsequent violations.
- The designated agency will run annual pay equity studies, collaborate with the Commission on Gender Equity, deliver recommendations to city leaders, and publish aggregated findings without identifying employers or employees.