NYC employers will soon be required to include a minimum and maximum salary on all job postings for positions performed within the City. As we previously reported, the City Council passed Int. 1208-B (Law) on December 15, 2021, and due to new NYC mayor Eric Adam’s inaction within the 30-day veto period, it became a law as of January 15, 2022. Beginning May 15, 2022, the Law requires employers with four or more employees to include a “good faith” minimum and maximum salary range on for all advertised NYC job, promotion and transfer opportunities. Additionally, the Law makes the failure to include salary range an unlawful discriminatory practice under the City’s Human Rights Law.
To prepare for compliance, employers and their agents (e.g., recruiters) should review their current processes for internal and external advertising and postings of jobs, promotions and transfers for positions located in New York City. Employers should revise templates as necessary to ensure salary ranges will be included for positions in NYC. In addition, with equal pay claims on the rise, employers may wish to use this as an opportunity to review how they determine salary ranges for positions in New York City (and elsewhere) and the relevant factors they rely on for determining compensation for their jobs.
We will provide an update if the City’s Commission on Human Rights issues guidance or regulations regarding the Law.