This past December, The New York State Assembly passed employment law changes that will significantly impact employers over the next upcoming years. These developments reflect a continued expansion of worker protections and increased compliance obligations for businesses all throughout New York State. From new restrictions on employment agreements, to expanded discrimination standards and pay equity reporting requirements, employers should begin preparing now to manage risk and maintain compliance.

Immediate Changes Affecting All New York Employers

New York Ban on “Employment Promissory Notes” – Effective December 19th, 2025

After Governor Kathy Hochul signed the Trapped at Work Act, New York now prohibits employers from requiring “employment promissory notes” as a condition of employment. These agreements usually require employees to reimburse their employer for training cost if they leave before a set period of time. While limited exceptions exist, violations may subject the employer to fines ranging from $1,000 to $5,000 per violation. Employers should immediately review onboarding documents, training repayment agreements, and bonus arrangements to ensure they comply with the upcoming changes.

Codification of Disparate Impact into NYSHRL – Effective December 19th, 2025

Gov. Hochul amended the New York State Human Rights Law to formally codify disparate impact discrimination. Under this standard, an employment practice may be deemed unlawful if it has a predictable or actual adverse effect on a protected group, heightening employer exposure and reinforcing the need to carefully evaluate neutral workplace policies.

Upcoming Statewide Changes in 2026

Restrictions on Credit Checks in Employment Decisions – Effective April 18th, 2026

Beginning in April 2026, New York State will significantly restrict employers’ ability to request or use consumer credit history when making employment decisions. Credit reports and scores will generally be prohibited unless an exemption applies, such as law enforcement duties, or access to sensitive financial or security systems.

New York City Employer Obligations in 2026

In December 2025, the New York City Council enacted new pay data reporting requirements for certain private employers after overriding a mayor Adams’ veto. Employers covered under this act will be required to submit compensation data that the city will use to conduct annual pay equity studies.

Increased New York City Earned Safe & Sick Time Act – Effective February 22nd, 2026

New York City employers will also see expanded obligations under the Earned Sick and Safe Time Act. These changes increase available leave, broaden qualifying reasons for leave, and streamline temporary schedule change requirements by consolidating them into ESSTA.

What This Means for Employers

These upcoming changes increase compliance complexity and enforcement risk for New York employers. Businesses should take proactive steps for the following:

• Employment agreements and repayment provisions
• Workplace policies for disparate impact risk
• Credit-based hiring decisions
• New York City pay equity reporting obligations
• Update employee handbook policies

Atlas, Clifford, et al. “New York State and City Legislative Update- Changes for All Employers in 2025 and 2026.” The National Law Review, National Law Review, 6 Jan. 2026, natlawreview.com/article/new-york-state-and-city-legislative-update-changes-all-employers-2025-and-2026.

At McIntyre, Donohue, Accardi, Salmonson, & Riordan LLP, we are a law firm committed to helping injured employers effectively navigate Workers’ Compensation across Long Island and New York State. If you or a loved one has been impacted by a workplace injury, MDASR is here to help.

Contact us at (866)557-7500 today to schedule a free consultation