NYC Council Passes Pay Transparency and Equity Bills
On October 9, 2025, the New York City Council approved and sent two bills to the Mayor’s desk for signature aimed at addressing alleged pay disparities at large New York City employers.
The first bill, Int 0982-2024, would require private employers with more than 200 employees working in New York City to submit a pay data report, including demographic and occupational information, to a designated agency. In determining the 200+ employee threshold, the bill counts all full-time, part-time, or temporary employees, based on when an employer has the highest total number of concurrent employees in a given year if the number of employees per week fluctuates.
If enacted, the bill would require that within one year of its enactment, the mayor designate an agency to create a system to collect the information, including a standardized fillable form. The bill describes that the information collected would need to include at least the information previously solicited by the EEOC in the EEO-1 component 2 (included for reporting years 2017 and 2018), though the amount of information requested may be increased. As a reminder, the EEO-1’s component 2 required covered employers to submit detailed pay data breakdowns by race/ethnicity and sex. Employers also have the option to submit explanatory remarks along with their submission. While the employer can submit the report anonymously, all employers will have to certify in a separate submission that the pay report and information they submitted is accurate.
The second bill, Int 0984-2024, would require that an agency be designated by the Mayor to conduct an annual pay equity study on those private employers with 200 or more employees. The bill specifically directs that such agency would generate the study in coordination with the commission on gender equity “and other relevant agencies.” The study would use the pay data information collected pursuant to Int 0982-2024 to assess whether there are disparities in compensation based on gender and race or ethnicity within certain industries. The study would also note “any trends in occupational segregation based on gender and race or ethnicity”. The agency would be required to submit a report to the Mayor and the City Council on the findings of the study, and it would also publish the information contained in the pay reports (though the bill provides that the publication must be done in a manner that does not reveal any particular covered employer’s or employee’s identifying information). The bill also requires that the report include recommendations regarding employer action plans for addressing disparities identified in the report.
Takeaways
If the bills become law, which seems likely, covered private employers will be required to submit annual pay data reports to a designated city agency. Employers who fail to comply will risk civil penalties and having their name posted on the relevant agency’s website as being non-compliant. The Firm will continue to monitor whether these bills become effective and the issuance of any subsequent guidance or forms. Employers should discuss with counsel whether they are covered by, and how best to comply with, the bills’ requirements, including what steps they should take to ensure they have accurate data for reporting purposes. Employers may also want to consider a privileged audit of their pay practices to assess whether there are any potential disparities and, if so, how best to remedy them.
Employers with questions about federal EEO-1 and New York pay equity measures should contact Jack Culhane at jculhane@fglawllc.com, Kristina Grimshaw at kgrimshaw@fglawllc.com or any other attorney at the Firm.
DISCLAIMER: This alert is provided to clients and friends of the firm for informational purposes only and the distribution of this alert is not intended to, and does not, establish an attorney-client relationship. This alert also does not provide or offer legal advice or opinions on any specific factual situations or matters. This communication may be considered Attorney Advertising. Prior results do not guarantee a similar outcome.