Blog · Updated July 2026
New York State Pay Transparency Law: Requirements & Penalties
New York has two separate pay transparency laws — a statewide law covering all of New York and a stricter local law covering New York City. Most employers know about one but not both. Here is what each requires and how they interact.
When most people search for “New York pay transparency law,” they find information about New York City’s Local Law 32. But New York State has its own separate law — Labor Law §194-b — that applies to every employer with four or more employees anywhere in the state. If your company hires in New York at all, both laws may apply to the same job posting.
New York State law at a glance
- Law
- New York Labor Law §194-b
- Effective date
- September 17, 2023
- Employer threshold
- 4 or more employees
- Required: salary range
- Yes — minimum and maximum annual salary or hourly range
- Required: benefits
- No
- Job description required
- Yes, if one exists
- Applies to internal postings
- Yes — promotions and transfer opportunities
- Penalty
- Up to $3,000 per violation (first offense curable within 30 days of notice)
- Enforced by
- New York Department of Labor
What the law actually requires
Every job posting, advertisement, or transfer opportunity must include the minimum and maximum annual salary or hourly wage the employer in good faith believes it would pay for the role. A single number does not satisfy the requirement. Neither does language like “competitive salary” or “depends on experience.”
If a written job description exists for the role, it must also be included in or linked from the posting. This is an unusual requirement — most other state laws only require the salary range.
The law covers internal postings too. Promotion and transfer opportunities shared with existing employees must also include the salary range and job description.
How it differs from NYC Local Law 32
New York City’s Local Law 32 has been in effect since November 2022 — nearly a year before the state law. The two laws are separate and operate independently. Here is how they compare:
| Feature | NY State §194-b | NYC Local Law 32 |
|---|---|---|
| Effective date | September 17, 2023 | November 1, 2022 |
| Employer threshold | 4+ employees | 4+ employees |
| Geographic scope | Any role performable in NY state | Any role performable in NYC (in whole or in part) |
| Salary range required | Yes | Yes |
| Benefits required | No | No |
| Job description required | Yes (if one exists) | No |
| Max penalty | $3,000 per violation | $250,000 per violation |
| Enforced by | NY Dept of Labor | NYC Commission on Human Rights |
The practical implication: a posting for a remote role open to New York applicants must comply with the state law. If that role could be performed from New York City specifically, it must also comply with Local Law 32. Both requirements apply simultaneously, and a single compliant salary range satisfies both — but the job description requirement from the state law is additional.
Common mistakes
- Updating only NYC postings. Many companies updated their NYC-specific postings in 2022 and assumed they were covered. The 2023 state law has a broader reach — any role open to New York applicants statewide requires a salary range.
- Skipping the job description. If your company maintains written job descriptions, they must be included or linked in every NY posting. This is often overlooked.
- Not updating internal transfer notices. Promotions and lateral moves posted internally also need salary ranges under both laws.
- Using OTE for sales roles. On-target earnings alone do not satisfy either law. Base salary range must be disclosed separately.
Enforcement and penalties
The state law allows a cure period for first-time violations: if an employer receives a complaint and corrects the violation within 30 days of notice, the first offense can be resolved without a penalty. Subsequent violations are subject to fines up to $3,000 per violation. NYC Local Law 32 has a similar first-offense cure period but carries a significantly higher maximum penalty of $250,000 per violation for repeat offenses.
Hiring in New York? Paste your job posting into the PayTransparency validator to check compliance against both NY State §194-b and NYC Local Law 32 simultaneously.