NYC Commission on Human Rights Issues Guidance on Salary Transparency Law
On March 22, 2022, the New York City Commission on Human Rights (NYCCHR) issued a fact sheet providing guidance on New York City’s newly enacted salary transparency law, which we reported on in February. The new law makes it an unlawful discriminatory practice for New York City employers with four or more employees (including independent contractors) to advertise a job, promotion or transfer opportunity for a position located within New York City without including a “good faith” minimum and maximum salary . As written, the law goes into effect on May 15, 2022; however, a bill recently introduced before the New York City Council would, if enacted, defer the effective date until November 1, 2022, and exclude employers with fewer than 15 employees (as opposed to the current four employee threshold)[1]. Below are some key take-aways from the NYCCHR guidance: We will continue to monitor developments relating to New York City’s salary transparency law. Please feel free to contact Natasha Lipcan at [email protected] with questions about this new law or its requirements. [1] This bill also would amend the current law by (1) omitting from its scope both general hiring notices that do not reference a particular position and positions that are not required to be performed, at least in part, in New York City; and (2) clarifying that both hourly and salaried positions are covered by the law. Natasha Lipcan (New York team) is an employment law attorney with more than 20 years of experience representing private employers in a broad range of employee-related matters. She handles a wide range of employment issues, including employment law compliance, organizational change, diversity and inclusion, employment-related agreements, arbitrations and litigations, wage and hour, workplace training and policies, and recruiting, hiring, managing and terminating employees.
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