On December 4, 2025, the New York City Council overrode a mayoral veto to enact Int. No. 982-A—which will require certain employers to annually submit an electronic pay data report—and Int. No. 984-A—which will require a designated agency to conduct an annual pay equity study based on the pay data reports (see HERE).
Employers already filing EEO-1 Component 1 reports may be wondering what more—if anything—is required. While similarities exist, New York City’s pay data reporting requirements are more detailed and pay-focused. For a quick comparison of reporting requirements, review these highlights below.
Focus
- NYC: Pay disparities in the private sector.
- EEO-1: Unlawful discrimination under Title VII.
Covered Employers
- NYC: Private employers with 200+ employees working in NYC.
- EEO-1: Private employers with 100+ employees (50+ for certain federal contractors).
Reporting Frequency
- NYC: Annually
- EEO-1: Annually
Data Collected
- NYC: Detailed pay and demographic data, including compensation by job category, pay band, race/ethnicity, and sex.
- EEO-1: Workforce demographic data, including data by job category, race/ethnicity, and sex.
Public Disclosure
- NYC: Publication of data reports in the aggregate.
- EEO-1: No publication of data reports, although the EEOC may publish aggregated data.
Employer Takeaways
While the laws took effect immediately, employers have some time to prepare. Since the mayor must first designate an agency to create and publish a standardized reporting form, employers likely will not be required to submit its first report until some time in 2028. In the meantime, employers can prepare by taking the following steps:
- Ensure accurate job classification mapping;
- Conduct a pay equity audit to evaluate compensation decisions;
- Evaluate internal pay practices to ensure compliance with federal and state pay equity laws; and
- Identify and address potential concerns or pay disparities prior to reporting.
If you have any questions related to NYC or federal data reporting requirements, or need assistance reviewing internal pay practices, please reach out to the NFC Attorney with whom you typically work or call us at 973.665.9100.