On April 28, 2022, the New York City Council (the “Council”) voted to delay the implementation of the new pay transparency law (the “Law”) that had been set to take effect May 15, 2022.  (See our previous bulletin, New York Employment Laws Taking Effect in May 2022.)  It will now be effective on November 1, 2022.

The amendment to the Law further confirms that the Law will apply to hourly and salaried positions, but not to positions that cannot or will not be performed, at least in part, in New York City.  In addition, per the amendment, an employee will have a cause of action for a violation of the Law only against a current employer and only in relation to a non-compliant advertisement by their employer for a job, promotion, or transfer opportunity.  Finally, under the amendment, monetary penalties will not issue for an initial violation if the violating employer or employment agencies, or their respective agents, prove that the violation was cured within thirty (30) days.