New York City’s Mayor, Bill de Blasio, has entered a far-reaching minimum wage executive order that affects many employers without their knowledge – and the City has not worked out how to let employers know that they are covered by the new requirements.

In late September, a New York City mayoral executive order immediately placed a $13.13 per hour minimum wage on businesses that are located in buildings that receive $1 million or more in city subsidies and do not offer health insurance to workers. For employers in such buildings that do offer health insurance, the minimum wage has been raised to $11.90 per hour. The Mayor has also expressed his intention to increase the minimum hourly rate under the order to $15.22 by 2019, and to lobby the state government for the authority to increase the state minimum wage on a city-wide level.

The order is expected to apply to an estimated 18,000 employees, including many restaurant and retail workers, over the next five years. Previously, it largely excluded retail employees and applied to some 1,200 workers. There are some exemptions to this order, including small businesses whose revenues fall below $3 million and buildings that have a certain percentage of their space filled with residential units. If you fear this order may affect you, your tenants, or a commercial property you are seeking to occupy, Kelley Drye’s Labor & Employment Practice will know – because the City won’t tell you until they find you have violated it.