As of February 1, 2025, covered employers under the Massachusetts pay transparency law, Chapter 141 of the Acts of 2024, will for the first time have to submit copies of EEO data reports to the Commonwealth. The Massachusetts Executive Office of Labor and Workforce Development has recently published FAQs about the law, offering important clarification as to employer obligations and information about compliance. The FAQs also connect employers to a new webpage for the Secretary of the Commonwealth providing instructions for filing and a link for uploading required reports (which will be accepted until Monday, February 3, as the February 1 deadline falls on a Saturday).

As discussed in MBJ’s original client alert on the pay transparency law, the 2024 Massachusetts law requires the filing of EEO data reports by covered employers, i.e., employers who employ more than 100 employees in Massachusetts at any point in the prior calendar year and are subject to the requirement to file workforce data information with the EEOC. The required data needs to include workforce demographic information categorized by race, ethnicity, sex, and job category. Covered employers do not need to create new reports or make changes to existing reports in order to comply; instead, a covered employer should file the same EEO data report filed with the EEOC.

The FAQs also clarify that workforce data reporting under the pay transparency law does not, at this time, need to include wage information. Wage...

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