The New York City Council has amended the New York City Salary Range Transparency Act (the “Act”). The Mayor has 30 days to sign the amended law. As discussed in our initial post, the Act amended the New York City Human Rights Law (“NYCHRL”), creating an obligation on employers to disclose salary ranges in job advertisements for any position located in New York City. We highlight the City Council amendments to the Act below.
The Law Now Goes into Effect on November 1, 2022.
The law, which was enacted on January 15, 2022, was initially slated to go into effect on May 15, 2022. The Council has since voted to delay the effective date until November 1, 2022 to provide employers with more time to prepare to comply. In the lead up to that new compliance deadline, employers should remain mindful that the New York City Commission on Human Rights – the agency that enforces the NYCHRL – previously released a Fact Sheet entitled Salary Transparency in Job Advertisements, which provides guidance on how the Commission interprets the law. Certain portions of that guidance – particularly the interpretation of covered listings and the information they must contain – will likely remain unchanged if and after the Commission provides updated guidance in light of the amended law. More on that guidance here.
The Core Obligation under the Law – Salary Range Disclosures – Remains Intact.
Even with the amendments, the NYCHRL will still make it an unlawful discriminatory practice for an employer...
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