On December 4, 2025, the New York City Council voted to override Mayor Eric Adams’ veto, enacting new local laws that significantly expand pay transparency obligations for private employers.

Under the new law, employers with at least 200 employees must report pay data, including demographic and occupational information, on an annual basis following a multi-year implementation period. Reporting will be phased in over several years, providing employers with runway to prepare before their first submissions are due to a yet-to-be-designated city agency. This agency will also be responsible for creating a reporting system and standardized form. Employers that fail to comply may face civil penalties and be publicly listed on the agency’s website.

Additionally, an associated measure directs the agency to conduct and publish a pay equity study, based on the reported information, to evaluate disparities and trends across industries and occupations. Only aggregated findings will be published to protect individual identities.

Jackson Lewis is closely monitoring these developments and will provide updates as details emerge. For questions about New York City’s new requirements and their potential impact on your organization, please contact a Jackson Lewis attorney.