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Quick Hits
- In July 2024 Massachusetts enacted An Act Relative to Salary Range Transparency, which includes a requirement that covered employers report their EEO-1 workforce demographic data to the state each year.
- Covered employers must use an online portal to submit their EEO-1 reports.
- The deadline to file the data for the 2025 reports is February 2, 2026.
The federal government requires certain employers to submit workforce demographic data in a report, called an EEO-1 form, each year. Under Massachusetts’s 2024 pay transparency reporting law, An Act Relative to Salary Range Transparency, employers that had one hundred or more employees in Massachusetts at any time during the prior calendar year (and which are subject to EEO-1 reporting obligations) must send their most recent EEO-1 report to the state each year. For the 2025 filings that are due by February 2, 2026, employers that file EEO-1 reports must determine if they had one hundred or more employees in Massachusetts at any time during calendar year 2025. The published materials do not discuss remote employees.
The state maintains a portal that employers must use to submit their most recent EEO-1 report.
The portal does not require login information, but it allows the direct upload of the reports through the provided link. The instructions direct filers to make sure the uploaded file name contains the legal name of the filing entity and the type of report being filed, such as EEO-1 reports. The instructions provide contact information for several agencies that can answer questions concerning the implementation and interpretation of the filing requirement. During the first year of filings the portal did not provide confirmations of filings. For this reason, filers may want to consider alternative means of confirming their filings have been made.
The Massachusetts Executive Office of Labor and Workforce Development (EOLWD) has published guidance in the form of frequently asked questions (FAQs) to help employers comply with the workforce demographic reporting requirements. The FAQs include a discussion of which report should be submitted.
The FAQs state in a special notice that the deadline to submit this year’s EEO reports is February 2, 2026.
Next Steps
Massachusetts employers may wish to make the necessary preparations to file the required reports with the state before the deadline using the online portal. As a reminder, EOWLD has stated that employers need only file the most recent EEO-1 reports they have, and they do not need to include any form of wage data. The filing platform for the 2025 EEO-1 reports has not opened yet.
Ogletree Deakins’ Boston office, Government Contracting and Reporting Practice Group, Multistate Advice and Counseling Practice Group, and Pay Equity Practice Group will continue to monitor developments and will provide updates on the Government Contracting and Reporting, Massachusetts, Multistate Compliance, and Pay Equity blogs as new information becomes available.
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