Massachusetts Pay Data Reporting: Requirements and Pay Equity Best Practices

ATTENTION HR professionals in Massachusetts! A major shift in how employers must report, handle, and talk about pay is underway. The Frances Perkins Workplace Equity Act, also known as the Act Relative to Salary Range Transparency, was signed into Massachusetts law in July of 2024. This effort targeted closing the wage gap, increasing transparency, and cultivating equitable workplaces.  

Whether you’re an HR director, compliance officer, or a member of an HR Team wearing numerous hats, understanding the “ins and outs” of this new law is a must. 

Here’s what you’ll learn in this article: 

1. A breakdown of Massachusetts Pay Data Reporting requirements 
2. Who must comply and what data needs to be submitted 
3. Proactive steps HR can take to stay compliant and confident 

What Is the Frances Perkins Workplace Equity Act and Why Does It Matter? 

Signed into law on July 31, 2024, the Frances Perkins Workplace Equity Act is named after the first woman to serve in a U.S. presidential cabinet and an advocate for workers' rights. The law adds serious momentum to the national push for pay transparency and equity, joining the ranks of states like California, Colorado, and New York. 

The law has two major pillars: 

• Annual workforce demographic data reporting 
• Pay range disclosure requirements for job postings and employment actions 

It also reinforces and expands the existing Massachusetts Equal Pay Act, which already prohibits paying employees differently based on gender for comparable work. Now, there's a sharper focus on proactive reporting, public accountability, and pay transparency. 

Who Must Comply with Massachusetts Pay Data Reporting Requirements? 

Covered employers who fall under at least one of the following categories must submit a pay data report. 

1. Employers with 100 or more employees in Massachusetts 

You are required to comply if you employed 100 or more employees physically working in Massachusetts during the prior calendar year. This headcount is specific to your Massachusetts workforce only and not your national or global headcount. 

• Employees include full-time, part-time, remote workers based in MA, and seasonal employees. 

• Independent contractors and employees from staffing agencies (leased workers) do not count toward this threshold. 

2. Employers subject to federal EEO-1 reporting 

Even if you don’t have 100 employees in Massachusetts, you must comply if you're required to file the federal EEO-1 Component 1 report. That includes: 

• Private employers with 100+ employees nationwide, or 

• Federal contractors with 50+ employees and at least one federal contract of $50,000 or more 

If you file an EEO-1 Report, Massachusetts requires that you submit a copy of your most recently filed Component 1 report as part of its reporting program. 

This dual threshold captures a broad range of employers and streamlines compliance by building on the existing federal reporting infrastructure. You must keep your data clean, current, and accurate. 

For additional specifics on eligibility and definitions, check out the Massachusetts Workforce Data Reporting FAQs. 

What Data Must Be Reported? 

Massachusetts requires employers to submit Component 1 of the federal EEO-1 report, which includes demographic data such as: 

• Number of employees by: 
• Race/ethnicity 
• Sex 
• EEO-1 job category (officials, managers, professionals, technicians, etc.) 

Component 2 data, which includes wage bands and hours worked, is not required as of yet. If the EEOC reporting implements Component 2 again, the Massachusetts statue will also follow suite and require component 2 information to be included. To stay alert to regulatory updates, subscribe to OutSolve’s weekly newsletter to get alerts like this delivered right to your Inbox. 

How Do You Submit the Report? 

In order to submit the report, employers must: 

• Submit the data electronically through the Massachusetts Executive Office of Labor and Workforce Development’s (EOLWD) reporting portal. 
• Provide it annually by the required deadline (see below section) 
• Include only employees based in Massachusetts, unless submitting a full consolidated EEO-1 report (if federally required). You can also submit an EEO-1 report for any of your Massachusetts based locations.  

The state may issue more instructions each year about formatting and submission details. 

Key Compliance Deadlines 

The first submission of the EEO report was due on February 1, 2025. Because the deadline fell on a Saturday, the effective due date was Monday, February 3, 2025. 

• Reporting is based on workforce data from the previous calendar year (2024) 
• The report must be submitted annually, likely in Q1, of each year going forward 
• Individual employer reports will not be made public. EOLWD will only publicly aggregate results. The EOWLD published its first aggregate workforce demographics report on June 1, 2025. 

We recommend setting reminders now and subscribing to updates from the Massachusetts EOLWD or a compliance partner like OutSolve. 

What About Massachusetts Pay Transparency? 

A second key component of the law takes effect October 29, 2025, and will impact hiring and promotions across the board for Massachusetts employers. 

Employers with 25 or more employees in Massachusetts must: 

• Include pay ranges in all job postings, both internal and external 
• Disclose the pay range when offering a promotion or transfer 
• Provide the pay range upon request to employees or job applicants 

Learn more about the Massachusetts Pay Transparency law requirements here. 

What qualifies as a “pay range”? 

It’s the annual salary or hourly wage range the employer reasonably expects to pay for the position. This does not have to include bonuses, commissions, or benefits, though you may disclose those voluntarily. 

Remote and hybrid roles performed in Massachusetts are included, so multi-state employers must remember this when listing jobs that could be filled by MA based applicants. 

What Happens If You Don’t Comply? 

For EEO Data Reports Violations: 

• First-time violations may result in a warning 
• Subsequent violations can lead to penalties ranging from $500 to $25,000, depending on severity and frequency 
• Enforcement is handled by the Massachusetts Attorney General’s Office 
• Until October 29, 2026, employers have two business days to correct deficiencies during a “cure period” before financial penalties kick in 

For Pay Transparency Violations: 

• Until October 29, 2027 covered employers will have two business days to cure defects upon receipt of a notice to cure letter from the Attorney General’s office.  
• After that: 
  • 1st offense: Warning 
  • 2nd offense: $500 
  • 3rd offense: $1,000 
  • 4th and subsequent: up to $25,000 

Best Practices for Staying Compliant and Confident 

Getting compliant doesn’t have to be overwhelming. Here’s what HR teams should do now: 

• Audit Your Compensation Practices 
  • Review pay by job title, department, gender, and race 
  • Address disparities and document explanations 
  • Benchmark your salary ranges against the external market 
• Standardize Job Descriptions 
  • Align roles across the org with clear responsibilities 
  • Incorporate pay ranges into job templates 
  • Review internal mobility policies for transparency 
• Train Hiring Managers and Recruiters 
  • Teach them how to communicate pay ranges clearly and legally 
  • Provide talking points or FAQs 
  • Emphasize the risks of ad-libbing or deviating from disclosed ranges 
  • Training should be ongoing for reinforcement and to communicate any updates to the law or company pay philosophy 
• Document Everything 
  • Archive your EEO-1 and MA pay data report submissions 
  • Save job postings and internal communications related to pay 
  • Build an internal salary range library to manage consistency 
• Stay Informed 
  • Subscribe to updates from EOLWD or consult with your legal/compliance partner, such as OutSolve 
  • Review your compliance strategy annually to adjust for any law changes 

How OutSolve Can Help 

You don’t have to go at it alone. OutSolve helps employers navigate both state and federal compliance, and we’re ready to guide you through Massachusetts’ new requirements. 

Our services include: 

• EEO-1 Reporting Support: Preparation, validation, and submission of accurate workforce data 
• Pay Transparency Readiness: Tools and guidance for implementing pay range disclosures 
• Pay Equity Analyses: Advanced statistical analysis to uncover and correct compensation gaps 

What Massachusetts Pay Data Reporting Means for Your Organization 

October’s pay transparency requirement is fast approaching. And with this law becoming an annual obligation, the time to act is now. 

By preparing early, standardizing practices, and leaning on trusted advisors like OutSolve, your organization can transform compliance from a burden into a strategic advantage, one that builds fairness, trust, and a more inclusive workplace. Join HR Gumbo City, our vibrant Slack community for HR professionals, to see how employers are preparing for the report and pay transparency requirements.