New York City Pay Transparency Law: A Complete Guide

New York City’s pay transparency ordinance is among the strictest in the country. Unlike some state laws that allow a cure period, the Commission on Human Rights (CCHR) actively monitors job boards and has issued notices of violation without waiting for employee complaints. If you post jobs in New York City — including remote roles open to NYC residents — you need to understand this law.

Quick facts

Law

Local Law 32 of 2022 (amending NYC Administrative Code §8-107)

Effective date

November 1, 2022

Employer threshold

4 or more employees (including owners, family members, and part-time workers)

Applies to remote

Yes — any role that can be performed in NYC, regardless of where the employer is based

Required disclosure

Good-faith minimum AND maximum annual salary (or hourly range for hourly roles)

Benefits required?

No — NYC requires salary range only, not benefits description

Maximum penalty

$250,000 per violation (for repeat/willful violations)

Enforced by

NYC Commission on Human Rights (CCHR)

What does the law actually require?

Every job posting, promotion announcement, or transfer opportunity must include both a minimum and maximum annual salary or hourly wage. You cannot list just a minimum, just a midpoint, or say “competitive salary.” Both ends of the range must appear.

The range must be a “good-faith” estimate of what you would pay someone who meets the job requirements. This does not mean you must pay every hire within the range, but the range must reflect what you genuinely expect to pay. An artificially wide range (e.g., $50,000–$300,000) may not satisfy the good-faith standard.

Who counts as an “employee” for the threshold?

The four-employee threshold includes all employees anywhere in the world — not just NYC-based workers. Independent contractors are not counted. If your New York City company has two NYC employees and two remote employees in other states, you have four employees and are covered.

Does it cover remote roles?

Yes — explicitly. The CCHR has stated that a remote role is covered if it can be performed in New York City, even if the employer has no NYC office. If you post a “Remote — US” role and do not exclude NYC applicants, Local Law 32 applies.

How are penalties assessed?

The CCHR gives first-time violators an opportunity to cure — correct the violation within a specified period — before a fine is imposed. Once a notice of violation is issued and not cured, fines can reach:

• $0 for a cured first violation
• Up to $125,000 for uncured or first intentional violations
• Up to $250,000 for willful or repeated violations

The CCHR has been unusually proactive: agency staff have submitted test applications for jobs that lacked salary ranges and filed complaints based on those tests. This is not a law you can rely on only receiving complaints from actual candidates.

NYC vs. New York State law

New York State passed its own pay transparency law (§194-b) effective September 17, 2023. Both the NYC and New York State laws apply to covered NYC employers — but the NYC law is stricter. NYC employers must comply with both; in practice, if you comply with the NYC standard, you generally satisfy the state requirement as well.