Massachusetts · Compliance · Updated April 2026

MA EEO data report: 100+ employees, annual. Feb 1 deadline.

The Pay Transparency Act includes a separate workforce demographic data reporting requirement. Employers with 100 or more Massachusetts employees who are subject to federal EEO-1 filing must submit their EEO-1 data to the Secretary of the Commonwealth annually by February 1. Some employers (public sector under EEO-4) report biennially. The data is the same federal EEO-1 data — no new fields. The state aggregates the data for public reporting on wage gaps. 2-business-day cure window through October 29, 2026. Penalties follow the same Pay Transparency Act escalation: warning, $500, $1,000, $7,500-$25,000.

Threshold
100+ MA employees
Deadline
Feb 1 annually
Cure window
Through Oct 29, 2026
Active

EEO Data Filing Workflow

Tracks 100-employee threshold based on MA-primary-place-of-work analysis. Generates EEO-1 mirror data for Secretary of Commonwealth. Tracks Feb 1 annual deadline plus 2-business-day cure window.

Track 100-employee threshold
Surface Feb 1 deadline approach
Always running

What those rules do as Feb 1 approaches.

The hero card configuration: Flag on threshold tracking, Critical on deadline approach.

Flag · 100-employee threshold tracking

Teambridge calculates the prior-year average MA-primary employee count. When the count crosses 100, EEO data reporting activates with the next Feb 1 deadline.

Critical · Feb 1 deadline approach

Starting in November, Teambridge surfaces the upcoming Feb 1 deadline as Critical. The federal EEO-1 data is mirrored to the state report; submission tracking confirms filing with the Secretary of Commonwealth.

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The rule, plainly stated

Federal EEO-1 mirror to state. 100+ MA employees. Feb 1.

The EEO data reporting requirement is procedurally simple — same data, different recipient — but the cure window expires before the pay-range cure window, so Feb 1 deadlines deserve close attention.

An Act Relative to Salary Range Transparency (2024); MGL c. 149 § 27C: Beginning February 1, 2025, every private employer with 100 or more employees in Massachusetts subject to federal EEO-1 reporting requirements shall submit their most recent EEO-1 report to the Massachusetts Secretary of the Commonwealth on an annual basis. Public sector employers subject to federal EEO-4 reporting shall submit their EEO-4 report on a biennial basis.

Coverage: 100+ MA employees + federal EEO-1 filer

Coverage applies to private employers with 100 or more employees in Massachusetts at any time during the prior calendar year, AND who are subject to federal EEO-1 reporting requirements (typically employers with 100+ employees federally). Public-sector employers subject to federal EEO-4 reporting submit on a biennial basis. The MA-employee count is calculated based on workers with primary place of work in Massachusetts.

Filing deadlines: annual (private) + biennial (public)

Private employers with 100+ MA employees must submit their most recent EEO-1 report to the Secretary of the Commonwealth by February 1 each year. The data is the same EEO-1 data submitted to the federal EEOC — no new fields, no separate methodology. The state aggregates submissions for public reporting on wage gaps and demographic patterns. Public sector employers under federal EEO-4 reporting submit biennially, following the federal EEO-4 cycle — different from the private-sector annual cycle.

On autopilot

Teambridge tracks the threshold and the Feb 1 deadline.

EEO data reporting is procedurally simple but the deadline discipline matters — patterns of late or missing reports compound quickly under the AGO escalating-fine structure.

01 · 100-employee threshold tracking

MA-primary count.

Teambridge calculates prior-year average MA-primary employee count. Crossings (99 → 100 or 100 → 99) trigger reporting requirement transitions with effective dates.

02 · Federal EEO-1 mirror generation

Same data, state recipient.

When the federal EEO-1 is generated for EEOC submission, Teambridge mirrors the data to the state report format. The state submission timing aligns with the Feb 1 deadline.

03 · Feb 1 deadline workflow

November-January preparation.

Starting in November, the Feb 1 deadline surfaces as Critical. Pre-submission validation checks data completeness; post-submission confirmation logs the filing.

04 · Cure window monitoring

AGO Notice to Cure events.

Notice to Cure events trigger 2-business-day cure clocks (through Oct 29, 2026). After Oct 29, 2026, the cure window expires and fines issue immediately on findings.

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FAQ

People also ask.

Who must file the EEO data report?
Private employers with 100 or more employees in Massachusetts at any time during the prior calendar year, who are also subject to federal EEO-1 reporting. Public sector employers under federal EEO-4 reporting file biennially.
What's the deadline?
February 1 each year for private employers (annual cycle). Biennial cycle for public sector EEO-4 filers, following the federal EEO-4 timing.
What data is required?
Same data submitted to the federal EEOC under EEO-1: workforce demographic breakdowns by job category, race/ethnicity, and gender. No new fields specific to MA.
Where do I submit?
Massachusetts Secretary of the Commonwealth. Workforce data report submitted via the Secretary's online portal. The federal EEOC submission is separate and additional — both required.
What if I miss the Feb 1 deadline?
Penalties follow the Pay Transparency Act escalating structure: warning (1st), $500 (2nd), $1,000 (3rd), $7,500-$25,000 (4th+). Through Oct 29, 2026, employers receive a 2-business-day cure window. After Oct 29, 2026, fines issue immediately.
Can the data be used against me?
The aggregated public data supports state investigations into wage gaps. Combined with disclosed pay ranges, it can support claims under the Massachusetts Equal Pay Act (MEPA) — which has a private right of action. Documented good-faith compensation practices are the best defense.
How does Teambridge handle this?
100-employee MA-primary threshold tracks continuously. Federal EEO-1 mirrors to state report format. Feb 1 deadline workflow surfaces in November with pre-submission validation. AGO Notice to Cure events trigger 2-business-day cure clocks.