As we previously reported, the New York City Council passed legislation in December 2021 requiring New York City employers to include a maximum and minimum salary in all job postings (for new jobs as well as internal promotions and transfer opportunities). Mayor Eric Adams returned the bill unsigned to the city council on January 14, 2022, which means the law will become effective in mid-May 2022. We anticipate that the city will issue guidance on the law closer to its effective date.

To ensure compliance with this new law, New York City employers should set salary ranges for all existing positions and be prepared to revise job postings accordingly. In addition, employers should begin reviewing any other related human resources documents (e.g., job descriptions and compensation policies) to ensure that any salary representations are consistent with the salary range set for a given position.