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NYC Enacts Private-Sector Pay Reporting Law With Citywide Equity Study Mandate

The measure sets a phased timeline that could push first reports to 2028.

Overview

  • Private employers with 200 or more New York City workers must submit annual pay data by job category, race/ethnicity, and gender using a standardized form modeled on EEO‑1 Component 2.
  • The mayor must designate a collecting agency by December 4, 2026, that will publish the reporting form within a year, after which employers will have one year to file their first report.
  • The law allows “anonymous” submissions but also requires a signed statement identifying the employer and certifying accuracy, creating unresolved questions about how anonymity will function.
  • Noncompliance triggers notice and at least 30 days to cure, public listing of employers who fail to provide the required certification, and civil penalties of $1,000 for a first offense and $5,000 for subsequent violations.
  • The designated agency, working with the Commission on Gender Equity and the Mayor’s Office of Equity and Racial Justice, must run annual pay equity studies, publish aggregated data without identifying employers or employees, and issue recommendations for employer action plans.