This week’s post was co-authored by Robinson+Cole Labor and Employment Group lawyer Kayla N. West.

New York City’s wage disclosure law is set to take effect on November 1, 2022. New York City is one of several state and local jurisdictions in the United States that have passed such laws recently. In fact, New York State’s legislature passed its own wage disclosure law in June of 2022, which is currently awaiting Governor Kathy Hochul’s signature.

As we have previously discussed, pay equity has become an increasingly salient issue for employers and lawmakers alike. As a result, there has been a recent wave of new legislation aimed at establishing equal pay for equal work among employees. State and local jurisdictions have enacted various pay transparency laws to help tackle the issue. These laws vary significantly in terms of where, when, how, and to whom the necessary disclosures must be made, as well as the specific information that must be disclosed. Further discussion on the breadth of these laws can be found here.

New York City’s salary disclosure law is one of the more robust laws that has been passed so far. The law requires that employers with four or more employees post the minimum and maximum annual salary or hourly wage for every advertisement for a job, promotion, or transfer opportunity that can or will be performed, in whole or in part, in New York City. As is the case with many pay transparency laws, violating New York City’s salary disclosure law may result in substantial costs for the employer (such as a civil penalty of up to $250,000).

Manufacturers should remain cognizant of their pay disclosure, notice, and posting obligations, especially if they have employees in different states and localities. Manufacturers may wish to review and revise applicable hiring and employment documents, materials, procedures, and processes and seek guidance from competent employment counsel to ensure compliance with relevant laws.

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