The New York City Pay Transparency Law is, as of November 1, 2022, in effect. As previously reported in our Blog on March 29, 2022 and May 6, 2022, the law requires all employers, with 4 or more employees, to include a "good faith" salary range in all advertisements for a job, promotion or transfer opportunity that is to be performed - in whole or in part - in NYC.

The following are additional requirements/clarifications of the Law:

• The Law covers full-time/part-time positions, interns, domestic workers and independent contractors.
• "Advertisements" include all written descriptions of an available job, promotion or transfer opportunity publicized to a pool of potential applicants including internal postings.
• The salary range must include both a minimum and a maximum salary (if employer has no flexibility, the minimum and maximum can be identical). 
• The stated amounts should be the annual salary or hourly rate. Other forms of compensation (e.g. bonuses, tips, commissions, insurance, over time pay, etc.) do not need to be included.
• The New York City Commission on Human Rights ("Commission") will investigate compliance with the new law (on its own and/or in response to complaints). 
• Potential applicants can file claims with the Commission or can file a lawsuit in court.
• The Commission will not assess a penalty for the first violation of the Law if cured within 30 days. However, the Commission may assess penalties of up to $250,000 for the first uncured violation and all subsequent violations.