The Commonwealth of Massachusetts has published frequently asked questions (FAQs) on its new pay transparency law requiring employers with 100 or more employees in Massachusetts during the prior calendar year to submit workforce data to the commonwealth by Feb. 1 each year, with the upcoming 2025 deadline extended to Feb. 3. Employers may, but are not required to, include non-Massachusetts employees in their submissions.
The Commonwealth of Massachusetts Executive Office of Labor and Workforce Development’s new FAQs focus on the Massachusetts Salary Range Transparency Act (MSRTA) and new reporting requirements. The FAQs include information for employers on requirements in the act to report wage and demographic data. Employers with 100 or more employees in Massachusetts during the prior calendar year must submit annual, industry-based “aggregate wage data reports” that include “workplace demographic and pay data categorized by race, ethnicity, sex and job category.”
Starting in 2025, covered employers must provide to the secretary of the commonwealth the information contained in their most recently filed federal EEO-1 report, although they may modify the report to exclude non-Massachusetts employees.
The FAQs make the following clarifications:
- Employers need not create new reports or make changes to their existing EEO-1 report. Employers may “file the same copy of the EEO report you filed with the EEOC [Equal Employment Opportunity Commission].” Employers have the option, however, to customize a report (if they so choose) to reflect the required data for only Massachusetts employees.
- Reports do not need to include pay data at this time because pay data is not part of the current EEOC reporting requirements. The FAQs clarify that if the EEOC decides to require pay data as part of the EEO-1 report in the future, “it would also become part of the required filing in Massachusetts.”
- Individual data will not be made public; only aggregated data will be published.
- The initial EEO-1 report is due by Feb. 1, 2025, and annually on the same date thereafter. Since Feb. 1 falls on a Saturday this year, reports will be accepted until Monday, Feb. 3, 2025.
Siobhan E. Mee and Anna K. Perocchi are attorneys with Morgan Lewis in Boston. Douglas T. Schwarz is an attorney with Morgan Lewis in New York City. © 2025 Morgan Lewis. All rights reserved. Reposted with permission of Lexology.
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