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On April 28, 2022, the New York City Council passed Int. No. 134-A, which revises Local Law 32, New York City’s previously enacted salary disclosure law. In order to become law, the bill must be signed by New York City Mayor Eric Adams. While the mayor has thirty days to consider the bill, timing is key as the current salary disclosure law is set to take effect on May 15, 2022. If the mayor signs the bill, the effective date of the salary disclosure law would be pushed back to November 1, 2022.

Importantly for employers, and as previously reported, the bill contains an explicit carveout for “positions that cannot or will not be performed, at least in part, in the city of New York.” Additionally, the bill seeks to clarify that salary range disclosure requirements apply to both hourly and salaried employees.

The bill also includes a few differences from the original amendment. For example:

  • Only employees would have a private right of action against their current employers for violations of the salary disclosure law.
  • The bill would not impose monetary penalties for a first violation of the law, so long as the employer remedies the alleged violation within thirty days.
  • The prior amendment’s definition of “employer” as fifteen or more employees is not included in the version of the bill that was passed by the committee. This means that the definition of “employer” under the current law as four or more employees, with at least one working in New York City, would be operative.

Key Takeaways

Because much is still unknown surrounding if, and when, the bill will be signed, employers may want to prepare to comply with Local Law 32 as currently enacted by May 15, 2022. However, employers might want to review the above requirements and think about how they might comply with the obligations in the revised law if the amendments become effective.

Ogletree Deakins’ New York office will continue to monitor developments with respect to the progress of the proposed legislation and its impact on the workplace, and will post updates on the New York and Pay Equity blogs as additional information becomes available. Important information for employers is also available via the firm’s webinar and podcast programs.


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