On October 9, 2025, the New York City Council passed amendments to local laws that, if passed, would impose new pay equity reporting obligations on certain private employers and require the city to conduct annual pay equity studies.  These measures are designed to identify and address wage disparities based on gender, race, and ethnicity. The amendments are now pending before the mayor, who has 30 days to sign, veto, or allow the amendments to become law automatically.

If the amendments become law, private employers with at least 200 employees that file EEO-1 Component 1 reports with the EEOC will be required to submit annual pay data reports to a city agency designated by the mayor. The data will align with information previously required under the EEOC’s EEO-1 Component 2 filings. The designated agency will be responsible for developing a reporting system and standardized form within a year of the law’s effective date. Employers will then have one year to submit their first reports and must file subsequent reports on an annual basis. Those who fail to comply risk civil penalties and being publicly listed on the agency’s website.

Additionally, the designated agency will conduct an annual pay equity study, analyzing the collected data to identify pay disparities and trends across industries and occupations. The agency will publicly release its recommendations, with any data presented in the aggregate to safeguard individual employee and employer identities.

Jackson Lewis is closely monitoring the status of these amendments and will provide updates as developments unfold.

If you have questions about New York City’s pending pay equity requirements and their potential impact on your organization, contact a Jackson Lewis attorney to discuss.