INTRODUCTION

New York City employers be aware: A new “NYC Salary Disclosure Law” will soon require employers to include a good faith salary range for every job, promotion, or transfer opportunity advertised. While the NYC Salary Disclosure Law is scheduled to take effect on May 15, 2022, it may now be pushed out to November 1, 2022 due to a recently introduced bill that would amend the new law, including the effective date.

The following article analyzes what employers need to know to ensure compliance with the NYC Salary Disclosure Law (Int. No. 1208-B), as currently in effect and as further elaborated by the NYC Commission on Human Rights (NYCCHR) in its recently issued guidance (NYCCHR Guidance). This client alert also discusses the proposed amendments to the law under the new bill (Int. No. 134).

BACKGROUND

The NYC Salary Disclosure Law is an amendment to the New York City Human Rights Law and is administered and enforced by the NYCCHR. The new law was passed by the New York City Council on December 15, 2021 and became enacted into law on January 15, 2022, when the mayor of New York City neither signed nor vetoed the new law by that date. Pursuant to the terms of the law, the salary disclosure requirements take effect 120 days after becoming law, i.e., on May 15, 2022.

COVERED EMPLOYER

Employers that have four or more employees, with at least one employee working in New York City, are covered by the new law (employers with one or more domestic workers are also covered...

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