NYC Contractors: A major new pay-reporting law just passed.
NYC enacted Int. 0982-A, requiring private employers with 200+ employees working in the city to submit annual pay data reports modeled after the EEO-1 Component 2 framework.
That means reporting annual pay, hours worked, job categories, sex, race, and ethnicity, along with a required signed accuracy statement.
Timeline:
• Effective now
• 1 year: City names the administering agency
• 2 years: Reporting form released
• 3 years: First annual report due
Penalties:
$1,000 for an uncured first offense, $5,000 for every subsequent offense - plus public posting as a non-compliant employer.
Why this matters for contractors:
Construction payroll involves job codes, craft classifications, union rates, premiums, fringes, multi-entity structures, and certified payroll reporting. All of those elements directly impact the quality and consistency of the data the City will ultimately require. The systems contractors use today will largely determine how difficult or seamless compliance becomes once the form is released.
Industry insight:
Some contractors and software providers have already built internal versions of EEO-style pay-band reporting to prepare for similar requirements in other jurisdictions. This early work shows that clean job categorization, consistent pay structures, and accurate project-level cost allocation are the biggest determinants of whether these reports can be produced reliably.
As NYC begins rolling out Int. 0982-A over the next three years, contractors may benefit from reviewing their classification methods, pay codes, and data structures now rather than waiting for the official form.
Sharing here purely for awareness as the implementation window is long - but the preparation work sits squarely in payroll, finance, and compliance workflows that many of us in CFMA already manage every day.
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Zack Green
Account Executive
Trayd
Boston, MA
(401) 575-3555
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