The twist that sets this law apart from routine compliance measures is what happens next. A city agency will analyze all the data annually, hunting for patterns in who gets paid what across different industries. The agency will publish findings identifying which sectors show the widest disparities and release recommendations for how employers should address gaps.
Companies that skip the reporting requirement face escalating consequences. First-time offenders get a warning and 30 days to fix the problem. Miss that deadline and the penalty jumps to $1,000. Any repeat violation costs $5,000. But the real pressure comes from public shaming: the city will post a list online of employers who fail to comply.
The timeline stretches across roughly three years from the December 4 enactment date. The mayor must first pick an agency to run the program, then that agency will design a standard reporting form, and finally employers will start filing annual reports. The first round of data will trigger a citywide pay equity study, with results landing on the mayor's desk and going public about 18 months later.
For HR teams, this means building new systems to pull compensation data, slice it by demographic categories, and meet annual deadlines. The law allows anonymous submissions through the online form, though the required executive certification still identifies the company.
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