New York City’s pay transparency requirements have already changed how employers advertise compensation. Now, the City Council is looking to expand those rules. With the passage of Int. 0982-A and Int. 0984-A, the City could become one of the first local governments to mandate annual pay data reporting modeled after the federal EEO-1 Component 2 structure.
If signed by Mayor Eric Adams, the new measures would require private employers with 200 or more employees working in New York City to report compensation and demographic data each year. The City would then conduct recurring pay equity analyses using that information. Together, these bills move pay transparency beyond job postings and into broader evaluation of pay practices and equity across the private sector.
Current Pay Transparency Requirements
New York State and New York City already require employers to disclose wage and salary ranges in job postings. These laws focus on front-end transparency—informing applicants about compensation when roles are advertised.
However, employers are not currently required to report pay data by race or gender, nor do public agencies have the authority to assess pay equity across employers. The new bills aim to close this gap by requiring aggregated compensation reporting and enabling the City to study pay disparities more systematically.
What Int. 0982-A Requires
Int. 0982-A would add a new Section 12-208.2 to the NYC Administrative Code. Employers with 200+ employees working in the five boroughs would need to file an annual pay data report with a designated City agency.
Reporting Format
The required report would mirror the EEO-1 Component 2 format used federally in 2017–2018. Employers would report:
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Employee counts by job category
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Total W-2 Box 1 earnings
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Total hours worked
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Breakdowns by race, ethnicity, and gender
The responsible City agency may also add gender identity options or other enhancements. Data will be submitted through a standardized electronic form. While employers may choose to submit the data anonymously, they must sign a separate attestation confirming accuracy.
No individual employee’s personal information will be disclosed.
Implementation Timeline
After the law takes effect:
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Within one year, the Mayor must designate a City agency to oversee the program.
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Within the following year, that agency must publish the standardized reporting form.
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One year after the form is available, Covered employers must begin annual submissions.
Penalties
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First violation: warning or $1,000 fine
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Additional violations: $5,000 each
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After a 30-day cure period, the City will publish a list of noncompliant employers.
What Int. 0984-A Adds
Int. 0984-A explains how the collected data will be used. The designated agency must:
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Conduct annual pay equity studies analyzing disparities across gender and race
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Identify patterns of occupational segregation
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Publish summary reports and recommendations for employer action
The City will share aggregate data publicly, without identifying individual employees or employers. Nonetheless, the published analyses may highlight industry-wide pay gaps and influence expectations for corrective measures.
Compliance Considerations for Employers
Employers with large NYC operations will need to ensure they can:
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Identify which employees fall within the NYC reporting requirement
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Collect accurate demographic data
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Align compensation records with standardized reporting categories
For multistate employers, the framework resembles reporting already required in California and Illinois—though New York City’s approach is expected to be more public-facing.
While the law does not penalize pay disparities directly, the public reports may increase reputational, employee relations, and stakeholder pressure to address gaps.
With overwhelming City Council approval, these bills are likely to become law. Employers should prepare early by reviewing HR and payroll data systems and evaluating internal pay structures.
Pay transparency in New York City is moving beyond job postings. Soon, employers may need to show not just what they pay—but how equitably they pay it.