Compliance Stuff

New York employers should soon have more clarity on the Empire State’s new law targeting “stay or pay” agreements – and more time to comply. The state legislature recently passed amendments designed to address ambiguities and potential overreach in the original statute enacted in December 2025. The Trapped at Work Act, signed by Governor Hochul late last year, was intended to protect worker mobility by prohibiting employment agreements that require employees to repay certain training costs if they leave the job before a specified period. These are known as “stay or pay” agreements . However, the law’s broad language raised concerns about its impact on common employment practices, such as repayment of tuition reimbursement, signing bonuses, and relocation packages. The new updates will better define the law’s application and carve out exceptions for these and other standard business arrangements. Here’s what you need to know about the act and the pending changes as we wait for the Gover...

Recent legislative developments in multiple states have targeted “ stay-or-pay” clauses—contract terms that obligate employees to repay certain bonuses and educational or training expenses if the employee does not stay for a required period of time. Historically, these provisions were intended to safeguard employer investments in training and onboarding. However, state lawmakers are increasingly viewing them as restrictive and unfair to workers. Employers, particularly those with employees across multiple states, should carefully examine current agreements and prepare for compliance with these evolving state standards to mitigate risk and maintain lawful practices. California Effective January 1, 2026,  California Assembly Bill 692 (AB 692)  prohibits employment contracts that require employees to repay employment related costs upon early separation. If the employer violates the law, they may be exposed to penalties, fees, or costs such as liquidated damages. The California le...

KEY TAKEAWAYS: Hochul signs laws that protect individuals who request a reasonable accommodation from retaliation and prohibit the use of a person’s consumer credit history in employment decisions Hochul also signs laws that memorialize disparate impact theories in the New York State Human Rights Law and that prohibit employers from conditioning repayment of costs for employee training if the individual fails to work for a certain time period Hochul vetoes bill that would amend the New York Labor Law to be liberally construed in favor of workers New York Expands the Human Rights Law to Protect Individuals Who Request a Reasonable Accommodation from Retaliation On December 5, 2025, Gov. Hochul signed the  Reasonable Accommodation Anti-Retaliation Rights Law , which expands the New York State Human Rights Law. This law amends Executive Law Section 296(7) to make it an unlawful discriminatory practice to retaliate against individuals who  request  a reasonable accommodation....

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...

In a significant development for employers across the Empire State, the New York Legislature passed Assembly Bill A584B/S4070B in the final days of the 2025 session. This bill is known as the “Trapped at Work Act” and would prohibit the use of promissory notes that require workers to repay amounts to employers if they leave their jobs before a specified period. The bill, which has passed both the State Senate and Assembly, awaits delivery to Governor Hochul for action—which can happen at any time before the end of 2025.  The Trapped at Work Act would amend the New York Labor Law by adding a new Article 37, which would prohibit employers from requiring employees to sign an “employment promissory note”—agreements that require employees to repay to their employers a sum of money if they leave their employment within a specified period of time, with particular emphasis on a repayment framed as a reimbursement for training. The bill deems such agreements “unconscionable, against public...

New York’s two-year 2025-2026 legislative session hit its midpoint in June, with lawmakers wrapping up the first year by passing a slew of workplace-related bills that now await action from Governor Hochul. As federal labor and employment policy faces uncertainty and shifting priorities, state-level activity is intensifying across the country as lawmakers perceive insufficient federal enforcement or rollbacks in worker protections – and New York is no exception. Here’s a summary of key bills and what employers need to know. Notable Bills Passed by Both Houses These bills have cleared both Senate and Assembly and are headed to the Governor’s desk. If signed, they will impose new compliance obligations on employers, many of which warrant immediate attention. Extended Anti-Discrimination and Retaliation Protections Ban on Credit History in Employment Decisions ( S3072/A1316 ):   Employers would be barred from requesting or using a candidate’s consumer credit history when making employ...