The New York City Commission on Human Rights published guidance for the recently enacted Local Law 32 of 2022, which requires salary transparency in job advertisements, effective May 15, 2022.

New York City enacted legislation on January 15, 2022, requiring all covered employers to include a minimum and maximum salary for the position advertised. Unfortunately, the legislative language is minimal and vague.

Much of the new guidance appears to be parallel to guidance Colorado provided for its salary disclosure law. Colorado is the only other jurisdiction that has issued such a broad salary disclosure law related to advertisements.

Summary

Key points from the guidance include:

• The New York City Commission on Human Rights asserts that an employer is covered if it has at least one employee who works in New York City (and at least four employees in total) or, in the case of domestic workers, just one employee in New York City.
• The law applies to any positions that can or will be performed, in whole or in part, in New York City (including jobs worked remotely from an employee’s home).
• The guidance applies to a broad range of workers, including full-time and part-time employees, interns, domestic workers, and independent contractors.
• The guidance defines “advertisement” as a written description of a job, promotion, or transfer opportunity that is publicized to a pool of potential applicants (such as internal bulletin boards, internet advertisements, flyers at a job fair, or...

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