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City councils

New York City Council Passes Pay Equity Reporting Amendments

Strategic Insights

— 2 min read

On October 9, 2025, the New York City Council passed amendments to local laws that would impose new pay equity reporting obligations on private employers and require annual pay equity studies. The measures aim to identify and address wage disparities based on gender, race, and ethnicity. The amendments are pending before the mayor, who has 30 days to sign, veto, or allow them to become law automatically.

The proposed amendments would require private employers with at least 200 employees that file EEO-1 Component 1 reports with the EEOC to submit annual pay data reports to a city agency designated by the mayor. Employers would have one year to submit their first reports and must file subsequent reports on an annual basis. Those who fail to comply risk civil penalties and being publicly listed on the agency's website. The designated agency would conduct an annual pay equity study, analyzing the collected data to identify pay disparities and trends across industries and occupations.

Key Takeaways:

  • The New York City Council passed amendments to local laws that would impose new pay equity reporting obligations on private employers.
  • Private employers with at least 200 employees that file EEO-1 Component 1 reports with the EEOC would be required to submit annual pay data reports to a city agency.
  • Employers would have one year to submit their first reports and must file subsequent reports on an annual basis.
  • Those who fail to comply risk civil penalties and being publicly listed on the agency's website.
  • The designated agency would conduct an annual pay equity study, analyzing the collected data to identify pay disparities and trends across industries and occupations.
  • The agency would publicly release its recommendations, with any data presented in the aggregate to safeguard individual employee and employer identities.
  • Jackson Lewis is closely monitoring the status of these amendments and will provide updates as developments unfold.

Statistics:

  • Private employers with at least 200 employees that file EEO-1 Component 1 reports with the EEOC would be required to submit annual pay data reports.
  • Employers would have one year to submit their first reports and must file subsequent reports on an annual basis.
  • Those who fail to comply risk civil penalties.
  • The designated agency would have one year to develop a reporting system and standardized form within a year of the law's effective date.

Sources:

  • Mondaq Ltd. (2025) - Tel. +44 (0)20 8544 8300 - http://www.mondaq.com
  • Jackson Lewis P.C. (2025) - 10050 Regency Circle Suite 400 Omaha NE 68114 UNITED STATES - Tel: 212545 4000 - E-mail: myupdates@jacksonlewis.com - URL: www.jacksonlewis.com

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