New York City to Mandate Race and Sex Pay Data Reporting

The New York City Council voted to override Mayor Eric Adams’ veto of a new law that will require private employers to report pay data by race, ethnicity, and sex. This move positions New York City at the forefront of pay transparency and equity initiatives, aligning with broader national trends and state regulatory efforts. On December 4^th, 2025, the Council overturned the Mayor’s veto related to sections 982-A and 984-A which will require covered employers to submit employee pay data (982-A) and a city-agency developed pay equity study based on the submitted employer data.

Key Provisions of the New Requirements

• Employer Coverage: Applies to private employers with 200 or more employees in New York City.
• Reporting Requirements: Covered Employers must submit annual reports detailing the number of employees and their pay, broken down by race, ethnicity, and sex and occupational categories. Employers who fail to submit the required information will face civil penalties and public disclosure of their non-compliance.
• Employer Certification: Employers will be required to submit a signed statement by an authorized company official certifying the accuracy of the submitted data. 
• Public Disclosure and Pay Equity Report: A NYC agency to be designated by the Mayor will publish aggregated employer pay data, increasing transparency and accountability. The agency will also be required to prepare an annual pay equity report of the employer-provided pay data to identify trends across industries and job segregation issues.
• Implementation Timeline: These requirements will be phased in over several years. The yet-to-be designated city agency must first create a reporting system and form.

Next Steps for Employers

With this move, NYC joins California, Illinois, and other jurisdictions in requiring pay data reporting as a tool to identify and address pay disparities. Employers should take steps now to prepare, focusing on the following best practices:

• Data Collection: Employers must ensure accurate collection and categorization of pay data by race, ethnicity, and sex. Employers also should review and update their occupational assignments to ensure all roles are appropriately categorized. This is an often overlooked but important compliance exercise.
• Proactive Pay Analyses: Employers should conduct a pay equity study now to understand and prepare for any risks associated with this new employee pay data report. Using the additional time ensures that you have time to both verify the accuracy of your data and make any pay adjustments before the first reporting cycle.