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Sunday, September 27, 2026

New York State Enacts Pay Transparency Law - Mintz

This New York State development follows in the footsteps of a similar New York City requirement, which went into effect on November 1, 2022 (and which we covered here), as well as similar initiatives in Albany, Ithaca, and Westchester County, which also came into existence in 2022, among the many others from around the country. The New York State law effectively extends similar requirements to nearly all employers with a presence in in the state, but it also includes some notable differences that NYC and other employers should appreciate. We cover the law and its provisions in detail below.

Overview

Codified in the New York Labor Law as §194-b, the law requires New York employers with four or more employees who advertise for a job, promotion, or transfer opportunity that can or will be performed, at least in part, in New York, to disclose:

  • The compensation or a range of compensation for such job, promotion, or transfer opportunity; and
  • The job description for such job, promotion, or transfer opportunity, if such description exists.

Importantly, the State law does not require employers to disclose additional information such as a general description of employee benefits, or information about bonuses, equity, or additional employee compensation for successful applicants, departing from the approach taken by some jurisdictions such has Colorado and Washington.

Further, advertisements for positions “paid solely on commission” are deemed compliant with the law’s range of...



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