Compliance Stuff

A federal judge just temporarily blocked California from extending its labor board’s authority into private-sector labor disputes traditionally handled by the National Labor Relations Board (NLRB). The December 26 decision blocks key portions of a 2025 California law designed to allow state intervention when the federal labor agency is stalled or inactive. For employers operating in California, especially those facing organizing activity or unfair labor practice (ULP) exposure, the ruling provides clear notice that the NLRB continues to control private-sector labor relations within California (and by extension, other states) in the vast majority of circumstances. How will this ruling reverberate across the country into other states vying to insert themselves into the labor law scene? Read on for a summary and a practical gameplan to approach the coming months. What Happened? California lawmakers  enacted AB 288  in response to an extended power vacuum at the NLRB, including ...

Similar to many changes in administration, the 2025 labor and employment landscape was defined by fragmentation followed by realignment . Federal agency authority faced significant constitutional challenges, while states and cities accelerated their own legislation on pay transparency, paid leave, and hiring practices. This year-end update provides insight into the most consequential developments for employers, focusing on the National Labor Relations Board’s (NLRB) shifting authority, new standards for employer liability, heightened scrutiny of artificial intelligence (AI), and a wave of new state and local mandates. Employers with multijurisdictional footprints should address these changes to refine and update compliance roadmaps for 2026. NLRB Authority and Leadership in Flux A divided D.C. Circuit panel held in Wilcox v. Trump, et al. , No. 25-5057 (D.C. Cir. Dec. 5, 2025) that statutory “for-cause” removal protections for NLRB members are unconstitutional because the Board exerci...

Missouri employers might feel confused about the upcoming minimum wage increase set to take effect on January 1. While voters passed Proposition A in 2024 to increase the minimum wage to $15 per hour and require most employers to provide paid sick leave for certain purposes, Governor Kehoe rescinded the statewide sick time mandate in 2025 and also did away with Proposition A’s annual adjustments for inflation . With this will-they-won’t-they legal landscape, many Missouri employers may feel lost about what is required of them when the calendar flips to 2026, but have no fear – your FP employment lawyers are here with the scoop on what you need to know. New Year, New Wage Missouri’s minimum wage will increase by $1.25 for the second year in a row on January 1, 2026, rising from $13.75 to $15.00 an hour . However, because of the new law signed by Governor Kehoe, the rate won’t automatically increase for inflation on subsequent January 1sts as originally anticipated . This increase wi...

Resources for Electronic Submission of Injury and Illness Data NOTICE: The deadline for timely submission of injury and illness data was March 2, 2025. Establishments who missed the deadline must still submit their data. Visit the  ITA Coverage Application  to determine whether you are required to submit this data. Source(s): Injury Tracking Application (ITA) | Occupational Safety and Health Administration . (n.d.). Www.osha.gov. https://www.osha.gov/injuryreporting/ ITA Coverage Application | Occupational Safety and Health Administration . (2022). Osha.gov. https://www.osha.gov/itareportapp Appendix B to Subpart E of Part 1904-Designated Industries for § 1904.41(a)(2) Annual Electronic Submission of Information from OSHA Form 300 Log of Work-Related Injuries and Illnesses and OSHA Form 301 Injury and Illness Incident Report by Establishments With 100 or More Employees in Designated Industries . (n.d.). Retrieved December 29, 2025, from https://www.osha.gov/sites/default/...

Seyfarth Synopsis:  As we close out 2025, Governor Kathy Hochul signed into law an amendment to the New York Labor Law, entitled the New York Trapped at Work Act, which bans “employment promissory notes ” and similar stay‑or‑pay clauses used as a condition of employment. The statute took effect  immediately  on December 19, 2025. New York’s  Trapped at Work Act  (the “Act”) prohibits employers from requiring workers or job applicants to sign agreements that obligate repayment if the worker leaves before a stated time period, including provisions characterizing repayment as reimbursement for training . These agreements are now deemed unconscionable, contrary to public policy, and unenforceable. What’s Prohibited Under the Act, employers may not require, as a condition of employment, any “employment promissory note” or agreement that (i) requires payment to the employer if the worker leaves before a specified time, or (ii) labels repayment as reimbursement for emp...

A significant set of U.S. state privacy law developments, all effective Jan. 1, will expand compliance obligations for companies operating nationwide. These developments fall into three principal categories: (1) new regulatory requirements adopted by the California Privacy Protection Agency (CPPA) under California‘s Consumer Privacy Act of 2018 (CCPA), which includes enforcement of privacy and security risk assessment requirements; (2) new comprehensive consumer privacy statutes in Indiana, Kentucky, and Rhode Island; and (3) statutory requirements in Delaware and Oregon mandating recognition of universal opt-out preference signals. Together, these changes reflect the continued maturation of state privacy regimes and reinforce the need for scalable, multi-jurisdictional privacy compliance programs, including clear risk assessment protocols. We start first with the CCPA Amendments and Regulatory Updates, given that many companies benchmark their compliance programs as a differential of ...

Puerto Rico (PR) OSHA has issued a public notice announcing revisions to the fines and penalties imposed on employers for noncompliance with adopted OSHA standards, effective as of November 3, the date of the notice’s publication. Under the updated penalty framework, willful or repeated violations carry a minimum fine of $11,823 and a maximum of $165,514 per violation. Serious violations are subject to penalties ranging from $1,221 to $16,550 per violation, while non-serious violations carry no minimum penalty and a maximum of $16,550 per violation. Employers that fail to correct a cited violation may be fined up to $16,550 per day until the violation is remedied. Failure to comply with posting notice requirements may result in penalties of up to $16,550. These revised penalty amounts are intended to align PR OSHA enforcement with federal OSHA standards and to strengthen deterrence against workplace safety and health violations in Puerto Rico. The adjustments were adopted pursuant to ...

New York has officially joined California at the forefront of US artificial intelligence regulation. Governor Kathy Hochul just signed a revised version of the Responsible AI Safety and Education Act (RAISE Act) into law on Friday, establishing strict safety obligations for developers of the most advanced AI systems. The final law is narrower and less punitive than the version passed in June, but still marks one of the most consequential state AI safety laws enacted to date . Here’s what businesses need to know about what actually became law – and some specific steps you can take in 2026 to prepare for the January 1, 2027 effective date. AI Regulation Focused on Catastrophic Risk: Who is Covered? Unlike most state AI laws and proposed laws that focus on bias, discrimination, or consumer deception, New York’s RAISE Act targets a very specific risk category: catastrophic harm caused by highly capable AI systems. The law applies to “frontier models,” the largest and most advanced AI sys...