On January 15, 2022, the New York City Council enacted Local Law 32 of 2022 (Wage Transparency Law or Law) to amend the New York City Human Rights Law (NYCHRL) to require that most employers include compensation data in their job advertisements. The Law was supposed to take effect on May 15, 2022, however, it faced criticism over a number of ambiguities, including undefined penalties. In response, on April 28, 2022, the New York City Council passed an amendment to the Wage Transparency Law. Among the biggest changes is that employers now have until November 1, 2022—more than six months—to ensure compliance with the Law’s requirements. If Mayor Eric Adams signs the Law, which he is expected to do, New York City will become the second jurisdiction in the country (the first being Colorado) to require employers to include minimum and maximum potential salary amounts for open positions in job postings.
The Wage Transparency Law makes it an “unlawful discriminatory practice” for an employment agency, employer or any employee or agent of any employment agency or employer to advertise a job, promotion or transfer opportunity without stating the minimum and maximum hourly wage or salary compensation in a job advertisement. Employers must list the compensation that it believes in good faith at the time of the posting it would pay for the advertised job, promotion or transfer opportunity. According to the factsheet on the original Law published by the New...
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