The Massachusetts Executive Office of Labor and Workforce this week published FAQs providing guidance on the pay data reporting provisions of the Pay Transparency Law that was signed into law last year. Here are a few key takeaways for employers regarding deadlines and submissions:
- The law requires Massachusetts employers with 100+ employees to submit their most recent EEO-1 Reports to the Massachusetts Secretary of State by February 1, 2025—a Saturday. The reports should be uploaded to an online portal available on the Secretary of State’s website. Since the annual deadline this year falls on a Saturday, reports will be accepted until Monday, February 3, 2025.
- There is not a state-specific form for Massachusetts so employers should submit to the portal the same EEO-1 form that they most recently filed with the EEOC. Employers are not required to submit W-2 income earnings, race/ethnicity, sex, and job category to the Commonwealth. The EEOC stopped collecting this data in 2018, and the Massachusetts Pay Transparency law was designed to follow the EEOC’s reporting requirements.
- Employers will be required to disclose salary ranges to prospective employees and internal candidates and on job postings starting on October 29, 2025. Guidance from the Attorney General on specific disclosure requirements is expected sometime this spring or summer. For more information on the salary range disclosure requirements of the new law, please see HRW’s August 13, 2024 Alert.
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