On December 4, 2025, the New York City Council voted to override Mayor Adams’s vetoes of two new laws that will require large employers to disclose certain race- and gender-related pay data. Bill 982-A will require employers to submit to the New York City government certain pay information that is broken down by employee race and gender. After the mayor designates an agency to collect this information within one year, that agency will have an additional year to develop a standardized form for the data collection. The law only applies to employers with 200 or more employees, and such covered employers will be required to submit data within one year after the form is published.
In addition to reporting the pay data, employers must also submit a signed statement certifying the “accuracy of the information contained in such report.” To the extent the employer submits such a certification, an employer may submit the data anonymously. The agency administering the program will publish a list of covered employers who are not in compliance with the certification requirement, and these employers will be subject to civil penalties that include a $1,000 fine for the first offense that is not cured within 30 days and $5,000 for each additional offense. The agency must notify an employer of non-compliance and provide at least 30 days to comply.
Bill 984-A is the companion to 982-A, and describes how the New York City government will use the pay data. Specifically, within one year of covered employers submitting their pay reports to the designated agency, and annually thereafter, the City will “evaluate the data contained in the pay reports submitted by covered employers . . . in order to evaluate whether there are disparities in compensation among employees based on gender and race or ethnicity, and if so, identify[] industries where disparities may be prevalent and any trends in occupational segregation based on gender and race or ethnicity.” Within six months of conducting that analysis, the agency will make “recommendations regarding employer action plans for addressing any disparities identified through such study.” The agency is instructed to “publish the data contained in the pay reports submitted by covered employers in the aggregate, and only in a manner that does not reveal any particular covered employer’s or employee’s identifying information.”
Although the legislation takes effect immediately, employers will not be required to submit the pay data reports until the Mayor identifies a responsible agency and that agency then issues a standardized data reporting format. Thereafter, employers will have one year to submit the reports. In the interim, employers should address whether their internal reporting systems can support this new reporting requirement, and whether any privileged pay equity analyses should be conducted.