As the calendar turns to 2026, those running New York businesses have a lot on their minds. Inflation, economic uncertainty, tariffs, rising supply chain and labor costs, immigration enforcement’s impact on the workforce. The list is long.
It is understandable some things may not show up high on the radar, but are important nonetheless. We tracked four late-year 2025 changes that will impact employers in 2026. It is critical employers are aware of these December changes so they meet these compliance obligations in 2026.
Here’s what employers need to know:
Prohibition on retaliating against individuals requesting reasonable accommodations
Gov. Kathy Hochul signed Senate Bill S3398 into law to amend the New York State Human Rights Law (HRL) because that law was silent on whether requesting a reasonable accommodation constitutes a protected activity for purposes of retaliation claims.
The HRL requires covered employers to provide reasonable accommodations to employees with disabilities and prohibits retaliation against employees who engage in protected activity.
Since the statute did not expressly state that requests for reasonable accommodations were protected, courts have frequently grappled with this issue and often concluded such requests did not qualify as protected activity.
The amendment aligns the HRL with the New York City Human Rights Law to expressly provide that requesting a reasonable accommodation constitutes protected activity. As a result, New York...
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