November 1, 2022, is nigh. The date is significant for most employers in the City of New York because NYC Local Law 32, the salary transparency law (“the Law”), takes effect on that day.

We have been discussing the trends in pay equity all year long, and if earlier advice hasn’t been taken by now, the time has come for New York City employers to put some new practices and procedures in place. We have been keeping a watchful eye on New York City’s Commission on Human Rights (“Commission”) for new guidance materials, but little has been published thus far. Here is what you need to know about the Law.

The Law Applies to Most NYC Employers

As amended and effective November 1, 2022, Local Law 32 adds new provisions to the New York City Human Rights Law. An employer with four or more employees (including owners) or one or more domestic workers will be covered by the Law if at least one employee works some of the time within New York City limits. The Law also includes independent contractors and family members of the employer working for the business as counting toward the threshold for a covered “employer.”

There Are Few Exclusions

Postings by temporary staffing agencies seeking workers to join their pool of temporary workers (or “temps”) not for specific job placement are not covered by the Law. Additionally, if the position cannot or will not be performed in New York City, then the Law does not apply—e.g., an NYC-based employer hiring for a position in its Pennsylvania...

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