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NYC Pay Transparency Law Delayed Until November 1

US Updates / May 22, 2022

Written By: Francine Alfandary and Austin Ochoa

The New York City Council amended the new pay transparency law, which was scheduled to go into effect on May 15. The amendment delays the effective date of the law until November 1, 2022 and makes additional changes.

As we discussed in our previous publication, the New York City pay transparency law requires all NYC employers with four or more employees in New York State (at least one of whom is in NYC) to include the minimum and maximum salary range in all advertisements for jobs, promotions, and transfers.  The salary range must be that which the employer believes in good faith, at the time of the posting, it would pay.[1]

The amendment makes the following changes.  Additional changes may be made before the law takes effect on November 1, 2022.

  1. A person would not be able to bring a lawsuit against an employer based on the pay transparency law unless that person is a current employee who is bringing an action against the person’s employer for advertising a job, promotion, or transfer without posting a minimum and maximum hourly wage or annual salary.
  2. The penalty for an employer’s first violation of the law would be $0. Employers would have 30 days to correct violations before being fined by the New York City Commission on Human Rights (NYCCHR).
  3. The law applies to employees who are either paid hourly or through an annual salary.
  4. Positions that cannot or will not be performed, at least in part, in New York City are exempt from the law.

The NYC City Council may further revise the pay transparency law before its November 1 implementation date.  Pearl Cohen will continue to monitor developments.


Please contact Francine Alfandary ( with any questions.


[1] Int. No. 1208-2018-B.