Update Applicable to:	Effective Date
All Employers with 200 or More Employees	December 4, 2025

What happened?

On December 4, 2025, the New York City Council overrode the Mayor’s veto and enacted Int. 982‑A (employer pay‑data reporting) and Int. 984‑A (citywide pay‑equity study) and took effect immediately; first filings will begin after the City designates an agency and publishes the reporting form.

Overview

Who is covered: Private employers with 200+ employees working in NYC (count the highest number of full‑time, part‑time, and temporary NYC employees at any point in the year).

What must be reported (Int. 982‑A): Annual submission modeled on Equal Employment Opportunity (EEO)‑1 Component 2 (2017–2018)— IRS Form W‑2 Box 1 wages and total hours worked, broken out by race/ethnicity, sex, EEO‑1 job category, and 12 pay bands. The City may add gender‑identity options.

How it is filed: Employers may submit the data anonymously but must also file a signed accuracy certification identifying the employer.

City study (Int. 984‑A): The designated agency will run an annual pay‑equity analysis, publish aggregate (non‑identifying) results, and issue recommendations for employer action plans.

Timeline (phased):

• By Dec 4, 2026: Mayor designates the administering agency.
• By Dec 4, 2027: Agency publishes the standardized electronic form.
• By Dec 4, 2028: First annual reports due (earlier if the City accelerates).

What is NYC’s Pay‑Data Reporting & Pay‑Equity Study? It is a two‑part system:

1. Employers report standardized pay and demographic data annually (Int. 982‑A).
2. The City analyzes aggregated results each year to identify pay disparities and occupational segregation, then publishes recommendations for employers (Int. 984‑A).

Why this matters

• Regulatory risk: Noncompliance triggers public listing and civil penalties ($1,000 first uncured offense; $5,000 subsequent).

• Operational effort: Requires hours for exempt employees, consistent job‑category mapping, and robust data governance.

• Reputation & equity: Citywide, public aggregate findings will spotlight industry pay gaps, prompting scrutiny from employees, unions, boards, and media.

• Multi‑jurisdiction alignment: Helps harmonize with California/Illinois/Massachusetts pay‑data regimes and existing NYC job‑posting pay‑range rules.

Action Steps for Compliance

• Confirm coverage: Validate NYC headcount and in‑scope entities/EINs.

• Map data fields: Ensure HRIS/payroll can pull W‑2 Box 1 wages, total hours (incl. exempt), EEO‑1 job category, race/ethnicity, and sex, and bucket pay into 12 bands.

• Close hours gaps: Build processes (or defensible estimates) for exempt hours.

• Set governance: Define anonymized data file procedures, accuracy certification, and authorized signatory.

• Pre‑test equity: Run an internal, privileged pay‑equity analysis; draft explanatory remarks (tenure, specialty roles, location differentials).

Source References

• New York Int. 982-2024-A – A Local Law to amend the administrative code of the city of New York, in relation to pay data reporting by private employers
• New York Int. 0984-2024-A – A Local Law to amend the administrative code of the city of New York, in relation to a study on pay equity for private employees
• New York Counsil – Press Release (December 4, 2025)

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