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NYC Council Overrides Mayor’s Veto to Enact Private‑Sector Pay Data Reporting

A phased rollout begins only after the Mayor names an oversight agency, followed by creation of a reporting system.

Overview

  • Private employers with 200 or more NYC employees must file annual pay reports disaggregated by race, ethnicity and sex under Int. 982-A.
  • The statute sets a three-step timeline: agency designation by Dec. 4, 2026, standardized form by Dec. 4, 2027, and employer reporting starting within a year of the form’s release.
  • The framework is modeled on the EEOC’s former EEO‑1 Component 2, likely capturing headcounts by job category, pay bands, W‑2 wages and hours, with optional explanatory remarks.
  • Data submissions may be anonymous, yet each employer must file a signed certification; noncompliance triggers a $1,000 fine after a 30‑day cure period and $5,000 for subsequent violations, plus public listing.
  • A designated agency, working with the Commission on Gender Equity, must publish aggregated findings and conduct annual pay equity studies with recommendations for employer action plans.