After the NYC Council voted to override a veto by former Mayor Eric Adams, New York City will soon require large employers to report pay data by employee race, ethnicity, and gender.

After the NYC Council voted to override a veto by former Mayor Eric Adams, New York City will soon require large employers to report pay data by employee race, ethnicity, and gender.

NYC Pay Data Reporting Coverage and Requirements

As we previously reported, while these new requirement take effect immediately, covered employers—i.e., employers with 200 or more employees in New York City (including full-time, part-time and temporary employees)—will have some breathing room, as the City must first implement the process for the submission of such information.

First, the law requires that an agency be designated within one year of the law taking effect (i.e., by December 4, 2026), at which point the designated agency has one year to develop a standardized fillable form for covered employers to submit pay reports.

Within one year of the designated agency publishing the standardized form, and annually thereafter, covered employers must submit to the designated agency:

• A pay report that includes current information corresponding with the categories of information required by the Equal Employment Opportunity Commission (EEOC) in the EEO-1 "Component 2" reporting requirements for reporting years 2017 and 2018; and
• A separate signed statement confirming the submission and accuracy of the pay report.

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