As previously covered, the New York Legislature voted in favor of the Trapped at Work Act in July 2025. As passed by the New York Legislature, the Trapped at Work Act would broadly prohibit use of promissory notes that require workers to repay amounts to employers if they leave their jobs before staying a minimum specified period, with certain specified exceptions. On December 19, 2025, Governor Hochul signed the Trapped at Work Act into law, making it effective immediately. She noted, however, that it was “ambiguous in important respects, and would have prohibited certain voluntary tuition assistance programs that provide real benefits to their participants.” As a result, the governor signed the bill into law via a “Chapter Amendment”—a New York legislative tool whereby the governor signs a bill into law on the condition the legislature make amendments to the law as written in the next legislative session.

On January 6, 2026, the New York State Assembly introduced a proposed chapter amendment to the Trapped at Work Act to address Governor Hochul’s concerns. If enacted, the proposed chapter amendment would significantly revise several provisions of the Act and would revise the original effective date clause so the Act would “take effect one year after it shall have become a law,” replacing the prior “immediately” language. The amendment’s substantive changes would therefore take effect on December 19, 2026.

If adopted, the amended Trapped at Work Act would maintain the...

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