Four months ago, New York City became the second jurisdiction in the country to require employers to include the minimum and maximum potential salaries for open positions in job postings. While passed with the intention of providing applicants greater transparency about potential pay (and to narrow the pay gap), the law contained ambiguities and provided only a short lead time before the effective date of May 15, 2022. This made it difficult for many employers to prepare adequately for the law, particularly since the New York City Commission on Human Rights was not able to propound regulations to clarify the law prior to the effective date. While there was support for the underlying sentiment of the law, many groups believed it was too broad and too punitive, with an undefined geographic scope and undefined penalties, especially in light of the fast-approaching effective date.
The New York City Council listened to these concerns, and on April 28, 2022, passed an amended version of the New York City Pay Transparency Law, Int. 134-A.
What’s Different?
Most importantly, the effective date of the law has been pushed to November 1, 2022, giving employers almost six additional months to bring their job.