This week’s post was co-authored by Robinson+Cole Labor and Employment Group lawyer Kayla N. West.

New York City’s wage disclosure law is set to take effect on November 1, 2022.  New York City is one of several state and local jurisdictions in the United States that have passed such laws recently.  In fact, New York State’s legislature passed its own wage disclosure law in June of 2022, which is currently awaiting Governor Kathy Hochul’s signature.

As we have previously discussed, pay equity has become an increasingly salient issue for employers and lawmakers alike.  As a result, there has been a recent wave of new legislation aimed at establishing equal pay for equal work among employees.  State and local jurisdictions have enacted various pay transparency laws to help tackle the issue.  These laws vary significantly in terms of where, when, how, and to whom the necessary disclosures must be made, as well as the specific information that must be disclosed.  Further discussion on the breadth of these laws can be found here.

New York City’s salary disclosure law is one of the more robust laws that has been passed so far.  The law requires that employers with four or more employees post the minimum and maximum annual salary or hourly wage for every advertisement for a job, promotion, or transfer opportunity that can or will be performed, in whole or in part, in New York City.  As is the case with many pay transparency laws, violating New York City’s salary disclosure law may result in substantial costs for the employer (such as a civil penalty of up to $250,000). 

Manufacturers should remain cognizant of their pay disclosure, notice, and posting obligations, especially if they have employees in different states and localities.  Manufacturers may wish to review and revise applicable hiring and employment documents, materials, procedures, and processes and seek guidance from competent employment counsel to ensure compliance with relevant laws. 

Photo of Abby Warren Abby Warren

As an attorney in Robinson+Cole’s Labor, Employment, Benefits + Immigration Group, I represent manufacturers in all areas of labor and employment law.  This includes discharge and discrimination issues, workplace investigations, affirmative action compliance, employee discipline, wage and hour issues, disability and reasonable accommodation…

As an attorney in Robinson+Cole’s Labor, Employment, Benefits + Immigration Group, I represent manufacturers in all areas of labor and employment law.  This includes discharge and discrimination issues, workplace investigations, affirmative action compliance, employee discipline, wage and hour issues, disability and reasonable accommodation, family and medical leave, unemployment, training, and defense in federal and state court and before administrative agencies. My full firm bio can be accessed here.

I represent manufacturers in the aerospace, consumer goods, machinery and other industries, which involves identifying practical, cost-effective and realistic solutions that prioritize and solidly execute the client’s objectives.  Manufacturers face unique challenges stemming from compliance with ever-changing industry regulations, including those impacting federal contractors.  Early in my career, I toured a client’s facility facing union-related struggles and realized that only through observing the workplace on the ground level can an attorney successfully understand and represent businesses.  As an employment attorney, I work alongside clients as a true partner to further their key personnel and human resources goals, including efficient and safe operations, recruitment and retention of talent, diversity and inclusion, among other issues. Whether advising on a leadership transition or on compliance with wage payment laws, the aim is always the same – to solve problems so clients can focus their attention on doing what they do best – manufacturing.