Massachusetts – 2025 Pay Data Reporting Deadline Approaching

This is a critical reminder for all employers with employees in Massachusetts regarding the upcoming Massachusetts Pay Data Reporting deadline. The reporting portal opened on January 16, 2025, and reports must be submitted no later than February 3, 2025 (the statutory deadline is February 1, but it has been extended since February 1 falls on a Saturday).

Who Is Required to File?

Under the Massachusetts Pay Data Reporting requirements, any employer that:

• Had 100 or more employees in Massachusetts at any time during calendar year 2024, and
• Is subject to federal EEO-1 filing requirements must submit their most recent EEO-1 Report to the state.

Unlike the pay reporting laws in California and Illinois, the Massachusetts law includes employees based outside of Massachusetts for certain employer types. Read more about requirements at our Massachusetts Pay Data Reporting Compliance Consultants webpage.

Key Reporting Details & Clarifications

• Which EEO-1 report should I submit?
  • If you are a multi-state employer, you must file an EEO-1 report that includes Massachusetts establishments.
  • There is no requirement to create a separate EEO-1 report solely for Massachusetts.
  • Employers may submit their consolidated report, headquarters report, establishment report, or any EEOC-required report that includes Massachusetts locations.
• Will wage data (Component 2) be required?
  • No. Since Component 2 wage data reporting was not reinstated by the EEOC, pay data does not need to be submitted for the 2025 filing.
  • Employers are only required to submit a copy of their EEO-1 report (without wage data).

Key Citation

The Massachusetts law (An Act Relative to Salary Range Transparency) defines a covered employer as follows:

“An employer with not less than 100 employees in the Commonwealth at any time during the prior calendar year and subject to the federal filing requirements of a wage data report.”

Additionally, the state FAQs clarify:

“Employers with 100 or more employees in the Commonwealth at any time during the prior calendar year are considered covered employers.”

If you are unsure about your filing obligations or need assistance preparing your submission, please reach out as soon as possible.

Given the tight timeline, we recommend submitting your report as soon as possible to avoid any last-minute compliance issues.