New York's Salary Range Disclosure Law: Tighter Postings, Uneven Enforcement

New York City's Local Law 32 of 2022 (effective November 2022) and New York State's Labor Law §194-b (effective September 2023) require employers with four or more employees to disclose a good-faith minimum and maximum salary or wage range in job postings, promotions and transfer notices. Enforcement of the city law sits with the NYC Commission on Human Rights (CCHR); the state law is enforced by the New York State Department of Labor.

In a report published 30 January 2025, the New York City Council's Oversight and Investigations Division analysed more than 60,000 unique job postings sourced from Indeed and Google for Jobs. It found that an overwhelming majority of postings kept maximum salaries below double the minimum — evidence that most employers were not gaming the law with meaninglessly wide ranges. Council Speaker Adrienne Adams said the law was "largely achieving what we intended upon its passage." The review also found that thousands of listings on Indeed and Google for Jobs were missing required salary data, but attributed this mainly to how those platforms scrape and re-post listings from other sources rather than to employer non-disclosure.

The same report found real gaps in enforcement: CCHR had opened more than 30 salary-transparency cases against major employers, including Tesla, News Corp, Indeed and ZipRecruiter, but had not announced the resolution of a single one by the report date, and the agency was operating with 112 of its 136 approved staff positions filled. Independent research summarised by the Federal Reserve Bank of Minneapolis likewise found that "compliance remains far from perfect in states that require transparency," citing New York postings with ranges as wide as $50,000–$180,000, and noted that enforcement in most US pay-transparency regimes relies on individual worker complaints rather than proactive audits.

Robust, causally-identified US evidence on whether the law has narrowed the gender pay gap itself was not found; the Minneapolis Fed review pointed only to "early evidence" of reduced gender pay gaps from pay-transparency laws in other countries, not from New York specifically.

Read the full analysis: https://council.nyc.gov/press/2025/01/30/2791/