Compliance guide

Massachusetts Wage Data Reports

Massachusetts requires employers with 100 or more employees in the Commonwealth who are subject to federal EEO filing requirements to submit a copy of that federal report to the Secretary of the Commonwealth each year.

It is the lightest-lift filing of any state pay-reporting regime - no separate state form and no new data collection. You file what you already filed federally.

There is also a separate, lower-threshold pay range disclosure requirement that applies at 25 employees. The two are commonly conflated.

Who files the wage data report?

Two conditions, both required:

  1. 100 or more employees in the Commonwealth at any time during the prior calendar year
  2. Subject to federal EEO filing requirements

What gets filed

The same copy of the EEO report you filed federally. Submitted through a web portal in PDF, JPG or PNG format, with filenames identifying the entity's legal name and report type.

When

The statute sets an annual schedule by report type:

ReportDue
EEO-1Annually, by February 1
EEO-3Odd-numbered years, by February 1
EEO-4Even-numbered years, by February 1
EEO-5Odd-numbered years, by February 1

On the February 1 versus February 2 confusion you may encounter: the deadline is February 1, extended to the next business day when February 1 falls on a weekend or holiday. February 1, 2026 was a Sunday, so that cycle's deadline was Monday, February 2, 2026. The same mechanism produced February 3 in 2025.

Write it as the rule, not the date - "February 1, or the next business day" is correct every year.

The separate pay range requirement

Different threshold, different subject:

  • 25 or more employees in Massachusetts
  • Effective October 29, 2025
  • A pay range is the annual salary or hourly wage range the employer reasonably and in good faith expects to pay for the position at that time
  • Required in job postings, to applicants, on promotion or transfer, when beginning a new position, and on an employee's request for their current role

Penalties

Identical structure for both requirements, with the Attorney General holding exclusive enforcement:

OffensePenalty
FirstWarning
SecondFine not exceeding $500
ThirdFine not exceeding $1,000
Fourth and subsequentPenalties under the general wage statute

A dependency worth flagging

This filing depends on the federal EEO report continuing to exist. Massachusetts requires you to file a copy of a federal report - and in July 2026 the federal agency published a proposal to rescind the EEO-1 and related reports entirely.

If the federal requirement disappears, it isn't obvious what Massachusetts employers file. The statute is written around a federal form.

Monitor this. Any content on this topic published before mid-2026 doesn't mention it, which is itself an opportunity - but it also means the position may change.

Frequently asked questions

Is the 100-employee threshold Massachusetts-specific?

Yes - 100 or more employees in the Commonwealth at any point in the prior calendar year.

Do we complete a separate state form?

No. You submit a copy of the federal EEO report you already filed.

When is it due?

February 1, or the next business day when that's a weekend or holiday.

Is the pay range rule the same requirement?

No. Different threshold - 25 employees - and it concerns disclosure in postings and to employees, not a filing.

What are the penalties?

Warning, then up to $500, then up to $1,000, then the general wage statute. The Attorney General enforces both.

What if the federal report is eliminated?

Unresolved. The state requirement is built around filing a copy of a federal form.

This guide is general information about reporting requirements, not legal advice. Verify current deadlines, thresholds and penalty amounts against the issuing agency before you file.