Coverage thresholds, what has to be disclosed and filed, by when, and what happens if it isn’t — for employers with people in New York.
New York City is about to become the second jurisdiction in the country to require private employers to file pay data. The law passed by veto override in December 2025, and the phase-in has already started running.
Employers with four or more employees must disclose compensation in any advertised job, promotion, or transfer opportunity.
Enacted 4 December 2025 by City Council veto override. Private employers with at least 200 employees working in New York City.
A New York employer is usually managing state and city obligations at once, and they do not line up.
State § 194-b catches employers at four employees. NYC Local Law 32 also catches employers at four employees (or one domestic worker) in the preceding 12 months, with at least one working in New York City — and the four need not all work in the city, nor in the same location. Owners and individual employers count toward the four. NYC Local Law 173, the new pay data reporting regime, sits far higher at 200 employees working in New York City.
NYC Local Law 32 explicitly prohibits open-ended ranges — “$50,000 and up” or “up to $50,000” are non-compliant. Where there is genuinely no flexibility, the minimum and maximum may be identical.
Coverage is broad: full-time, part-time, intern, domestic worker, and independent contractor positions, across every medium including internal bulletin boards and printed flyers, for any role that can or will be performed at least in part in the city — including remote roles. Positions under a collective bargaining agreement are covered. Health and life insurance, time off, retirement contributions, severance, overtime, commissions, tips, bonuses and stock need not be listed.
A first NYC complaint carries no civil penalty if the employer cures within 30 days of service and submits proof. But submitting proof of cure is deemed an admission of liability for all purposes. That is an unusual provision and it deserves counsel’s attention before anyone files proof of correction reflexively. Uncured or subsequent violations reach civil penalties of up to $250,000 under the NYC Human Rights Law.
Local Law 173 reporting is modelled on EEO-1 Component 2 — wage data and total hours worked by race, ethnicity, sex, and job category across 12 pay bands. Component 2 was collected federally only for reporting years 2017 and 2018, and most employers found it genuinely difficult then.
The work that makes it tractable — consistent job categorisation, clean hours data for exempt staff, reconciled demographic records — takes 12 to 18 months in a large organisation. Employers who wait for the agency to publish its form will have about a year, and will be building job architecture and filing in the same window.
The original state bill would have required employers to keep the history of compensation ranges and job descriptions for each advertised opportunity. The March 2023 chapter amendment removed that requirement, so there is no statutory recordkeeping mandate under § 194-b. Many employers retain the records anyway, for the straightforward reason that defending a good-faith range is easier with contemporaneous evidence than without.
There is also no state-level pay data reporting obligation for private employers. That is a city requirement only.
We support New York employers on the compensation side of this — pay equity analysis, range architecture, and how executive pay reads inside a filing or a published range. We are not attorneys and this page is not legal advice; the filings themselves are usually handled with employment counsel.
For advisory work in the region, see our New York City executive compensation page.
The law is enacted but filings have not started. Local Law 173 of 2025 was passed by City Council veto override on 4 December 2025 and took effect immediately, but with a phase-in: the Mayor designates an administering agency by 4 December 2026, that agency publishes a standardised form within a year, and employers file within a year after that — so first filings are expected around 2028. It applies to private employers with at least 200 employees working in New York City.
No. Both the state law and NYC Local Law 32 require a good-faith minimum and maximum. The city law explicitly prohibits open-ended ranges. Where there is genuinely no flexibility on pay, the minimum and maximum may be stated as the same figure.
Generally yes, where the role could be performed in New York or reports into a New York supervisor, office or worksite. The specifics vary — some states test on where the work is performed, others on the reporting line, and several catch out-of-state employers recruiting locally-based remote staff. Check the coverage language above against your own arrangements rather than assuming a headquarters test.
No. It is a compensation practitioner's summary of published requirements, current as at July 2026, intended to help you scope the compensation work these obligations create. Pay legislation in this area has been amended frequently and several provisions carry sunset dates. Confirm current requirements with employment counsel before acting.
Pay equity analysis and range architecture, sequenced so findings can be acted on rather than merely disclosed.
Tell us what you’re working through and we’ll follow up directly.