Last week, on November 1, 2022, New York City's pay transparency law became effective. The law amends the New York City Human Rights Law (NYCHRL) to make it unlawful for a New York City employer to advertise a job, promotion, or transfer without including the minimum and maximum salary for the position.

We have previously reported on this law here and here, as well as similar laws in other jurisdictions, including the still-pending New York State pay transparency law.

With the new law in already effect, some New York City employers have begun to publish salary/wage ranges in their open job postings. Others have not.

Here are key highlights for employers (including those that may think they are not New York City employers) to consider concerning the new law:

• Covered employers includes those with at least four employees or independent contractors, if at least one works in New York City.
• It applies to both external and internal job postings, including opportunities for promotion or transfer.
• It applies to positions that can or will be performed, in whole or in part, in New York City (i.e., if it is a job that could be filled by a remote worker in New York City, then the posting requirements apply even if employer is not NYC-based but is otherwise a "covered" employer under above terms).
• For the posted job, the employer must disclose the base annual or hourly wage rate of pay, and does not need to include other forms of compensation or benefits, such as health insurance,...

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