The Clock Is Ticking: Massachusetts Annual EEO Data Submission Deadline Is Near

On July 31, 2024, the Massachusetts Wage Transparency Act—officially titled An Act Relative to Salary Range Transparency—was signed into law to increase transparency around pay practices. Employers have two primary compliance obligations under the law: (1) a regular EEO data submission to the state and (2) providing pay ranges in job postings to increase pay transparency. We have previously written an overview of the legislation in a September blog post. 

Importantly, the EEO data submission deadline for covered employers is fast approaching, with reports due by February 2 this year. Employers should keep the following key points in mind when making the required submission:

Who is impacted?

Covered employers with 100 or more employees in Massachusetts (at any point during the prior calendar year) must submit their most recent federal EEO report. Employers who file EEO-1 reports must submit this data to Massachusetts annually. EEO-3 and EEO-5 filers submit data in odd numbered years (so no submission is due this year) while EEO-4 filers submit data in even numbered years.

What to file?

For 2026, employers only need to file the same EEO report already filed with the EEOC, which includes information about the race, ethnicity, and sex of your workforce by specific occupational categories. Although the Massachusetts law contemplates that wage data would also be reported, this would only become part of the filing requirement if EEOC decides to re-implement Component 2 of the EEO-1 report which collected W-2 income by pay band for included.

What is the deadline?

Reports are due February 1 each year, or the next business day if it falls on a weekend/holiday. For 2026, the deadline is February 2 (since February 1 is a weekend).

How do you file?

Reports must be uploaded in PDF, JPG, or PNG format through the Secretary of the Commonwealth's EEO Data Portal

What’s next?

Massachusetts will aggregate and publish anonymized, industry-level data on its Workforce Data Interactive Dashboard. The 2025 dashboard summarizes information from the 3,014 EEO-1 forms and 35 EEO-5 forms submitted last February by industry, job category, and county. The dashboard also includes key findings and a downloadable report.

What steps can employers take to stay ahead?

With the February 2, 2026, EEO-1 reporting deadline quickly approaching and salary range disclosure requirements already in effect, Massachusetts employers should view pay transparency as an ongoing compliance initiative—not a one-time task. Employers should make sure to submit their required EEO reports by this year’s reporting deadline. Employers may also want to review the state’s dashboard and key findings to understand In addition, by reviewing job postings, strengthening internal processes around pay transparency and salary decisions, and equipping HR teams with clear guidance, organizations can align with the law’s intent to promote workplace fairness while avoiding costly penalties.