Companies with More than 200 Employees Must Submit Annual Pay Data

In an effort to promote wage transparency and to determine the potential for pay disparity based on suspect classifications, such as gender, race or age, New York City has enacted a new law that requires disclosure of compensation, as well as demographic and occupational information. Applicable to employers with more than 200 employees, the law establishes a timeline for compliance:

  • The New York City Mayor must, by December 4, 2026, identify a city agency that will administer the law and perform any required pay equity studies of private workforces
  • Within a year of that determination, the agency must formulate a standardized form, as well as submission procedures, allowing employers to anonymously submit the required pay data. Employers must, however, swear to the accuracy of any information provided and must submit certified identification documents.
  • Once the standardized form is available, employers will have one year to begin filing annual pay data reports. Failure to meet the deadline may result in significant fines.

Though it may potentially be a couple of years before actually reporting is required, employers who will be subject to the new law should take steps now to put measures in place to facilitate tracking of pay, demographic and occupational information.

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