Takeaways

• The New York “Trapped at Work Act” bars employers from requiring employees to enter into “employment promissory notes” as a condition of employment.
• Out of caution, employers should treat 12.19.26 as the compliance date for agreements executed on or after that date. The Act is silent on whether it applies retroactively.
• Agreements that do not fit one of the amendment’s carve-outs, including certain tuition repayment agreements and “stay-or-pay” provisions, will be void; and employers may face penalties.
• Employers should review their repayment programs and agreements now.

Related links

• NY Trapped at Work Act’s Narrowed Scope + Delay: Impact on Employer Repayment Agreements
• New York A9452

Article

Gov. Kathy Hochul signed the New York “Trapped at Work Act” on Dec. 19, 2025, and it was swiftly amended (A9452) on Feb. 13, 2026. The amendments narrowed the law’s scope and changed when it takes effect. (For a detailed discussion of the amendment, see NY Trapped at Work Act’s Narrowed Scope + Delay: Impact on Employer Repayment Agreements.) With the compliance deadline potentially as early as Dec. 19, 2026, New York employers should shift now from monitoring the law to implementing compliance measures.

The New York State Department of Labor (NYSDOL) is expected to issue further guidance before or shortly after the effective date; however, as of this writing, none has been issued.

When Does the Act Take Effect?

As originally enacted, the Act took effect...

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