New York Employer 2025 Checklist: Top 10 Changes to Know This January

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  Key New York Change Employer To-Dos (1) Paid Prenatal Leave Now Required | Effective Jan. 1, 2025, private New York employers must provide employees with 20 hours of paid prenatal personal leave (PPPL) during any 52‑week calendar period in addition to paid sick and safe leave (PSSL). New York is the first state in the US to require employers to provide such leave.

PPPL is leave taken for health care services received by an employee during their pregnancy or related to such pregnancy, including physical examinations, medical procedures, monitoring and testing, and discussions with a health care provider related to the pregnancy.
Importantly, eligible employees can take all 20 hours of PPPL they are entitled to for the 52-week period starting the effective date of the new law–without waiting for PPPL to accrue.

For more details on the law’s requirements, see our previous blog here.

Update policies and practices to comply with the new requirements.

Modify handbooks as necessary, and train HR and managers / supervisors on the law’s requirements.

Review the New York State Department of Labor’s (NYSDOL) guidance on the law, including the FAQs and Employer Fact Sheet.  

(2) Minimum Wage Hike | Effective Jan. 1, 2025, the hourly minimum wage for workers (with the exception of tipped hospitality service workers and food service workers) increased to $16.50 in New York City, Westchester County and on Long Island (up from $16.00), and in the rest of the state the minimum wage increased to $15.50 (up from $15.00).

The minimum wage will increase again on Jan. 1, 2026 to $17.00 for New York City, Long Island and Westchester, and $16.00 for the rest of the state.

Beginning Jan. 1, 2027, minimum wage increases will be tied to the three-year average of the regional consumer price index–meaning economic conditions could prevent a minimum wage rate increase for a particular year. If the NYSDOL determines a rate increase is appropriate, it will post the adjusted rate no later than Oct. 1 of the year prior to the planned increase to allow employers adequate time to prepare.

Confirm with HR, payroll, and accounting that all wage rates comply with the law.

Post the required updated Minimum Wage Poster (available on the NYSDOL website here) in a visible location for employees.

(3) Increase in Overtime Exempt Salary Thresholds | The minimum salary threshold increased for the executive and administrative exemptions from overtime pay.

Effective Jan. 1, 2025, the salary threshold is $1,237.50/week ($64,350 annually) in New York City, Westchester County and on Long Island, and
$1,161.65/week ($60,405.80 annually) in the rest of the state.

The salary threshold will increase again on Jan. 1, 2026 to $1,275.00/week ($66,300 annually) for New York City, Westchester County and Long Island, and $1,199.10/week ($62,353.20 annually) for the rest of the state.

New York does not impose a higher salary threshold than federal law for employees employed in a “bona fide professional capacity.” Therefore, salary threshold for the professional exemption under New York law remains aligned with the federal professional exemption salary threshold, which is currently set at $684.00 per week ($35,568.00 annually).

Conduct a review to determine if the new higher exempt salary thresholds will affect the exempt status of employees. Determine whether to reclassify exempt employees as non-exempt, or to adjust the base compensation of affected exempt employees to ensure they continue to meet the applicable exemption criteria. Consult with counsel before making changes to consider all possible implications.   (4) Workers’ Compensation Now Covers “Mental Injury”| Under S6635 (effective Jan. 1, 2025), the state workers’ compensation law allows all workers to file claims for mental injury premised upon extraordinary work-related stress.

Prior to the amendment, only a small subset of first responders could obtain workers’ compensation benefits for mental injury.        

Update workers’ compensation policy coverage to include coverage for all employees alleging mental injury claims based on work-related stress.

Monitor developments on what “extraordinary work-related stress” means. It is not defined in the law.

Consult with counsel if faced with an employee claim of employment-related emotional distress outside of workers’ compensation, to determine whether workers’ compensation may be the exclusive remedy.

(5) Employers Must Include Notice Regarding Reproductive Health Care Choices in Handbooks | On Jan. 2, 2025 in CompassCare v. Hochul, the US Court of Appeals for the Second Circuit vacated a permanent injunction that had halted a requirement under N.Y. Labor Law § 203-e that employers include a notice in employee handbooks regarding the prohibition of discrimination for an employee’s or dependent’s reproductive health care choices.

As a result of the court’s decision, New York state employers are once again required to include the notice in their handbooks.

Review employee handbooks and update as necessary to include the notice of employee rights and remedies required under N.Y. Lab. Law § 203-e.     (6) Warehouse Employers Required to Take Steps to Reduce Injury Risk by June | The Warehouse Worker Injury Reduction Program (S5081C) takes effect Jun. 1, 2025, and will require covered employers to take steps to reduce the risk of musculoskeletal injuries and disorders among workers involved in manual materials handling jobs –including implementing an injury reduction program to minimize risks of injuries.

Covered employers
Employers who employ over 100 employees at a single warehouse distribution center, or more than 1,000 employees across multiple warehouse distribution centers within New York, are covered by the law.

Injury reduction program
The law requires employers to implement an injury reduction program, which must include a worksite evaluation; control of exposures (including the pace of work) which have caused or have the potential to cause musculoskeletal injuries and disorders; employee training and involvement; and on-site medical and first aid practices.  

Worksite evaluation
Employers must ensure that each job or process covered by the law has a written work site evaluation by a qualified ergonomist for risk factors causing musculoskeletal injuries. Employers must also determine if employees exposed to these risks face adverse actions due to quotas. Employers must collect recommendations from workers on possible risk factors and possible changes to mitigate the risk factors. The required initial evaluation must take place by Nov. 28, 2025, and must be reviewed and updated at least annually, with new analyses within 30 days of any job changes.  

Correction of risk factors
Employers must promptly correct any identified risk factors causing or likely to cause musculoskeletal injuries. If corrections take more than 30 days, employers must provide a schedule for the proposed corrections. Employers must minimize exposure as much as feasible if elimination of risk factors is not possible.  

Injury reduction training
Employers must provide injury reduction training to all employees involved in manual materials handling jobs and supervisors–including training on early symptoms of musculoskeletal injuries, methods to reduce risks, and employees’ rights to report concerns. The training must be conducted at the warehouse during normal work hours, without loss of pay for employees. The training must take place on or before Jul. 31, 2025.  

On-site medical office / first aid station
Any on-site medical office or first aid station treating workers with musculoskeletal injuries must be staffed with qualified medical professionals–and employers must consult with a licensed medical consultant for evaluations and recommendations. Employers must comply with these requirements by Jul. 31, 2025.  

Covered employers should prepare to meet the law’s requirements in advance of the compliance dates, including preparing an injury reduction program and the required training, obtaining a worksite evaluation, and developing a protocol for obtaining the required recommendations from workers on risk factors and possible mitigation.  

Employers should train HR and supervisors/managers on the law’s requirements.  

(7) Violence Prevention Required by Retail Employers by March | Under S8358C, by Mar. 3, 2025, each retail employer in New York with at least 10 employees working at a retail store (not primarily engaged in the sale of food for consumption on its premises) must:

(i) Adopt and implement a written workplace violence prevention policy, which must be provided to all employees upon hire and annually;
(ii) Provide workplace violence prevention training for employees (upon hire and annually) that includes information on de-escalation tactics, active shooter drills, and emergency procedures among other topics; and
(iii) Provide their retail employees with written notice of the workplace violence prevention policy and training program in English and the employee’s primary language.

By Jan. 1, 2027, retailers with more than 500 retail employees must also create a panic button system employees can use to trigger an alert if they believe they or a colleague is in an unsafe situation.

A proposed amendment to the Act is pending in the New York State Assembly (A1678). Among other requirements, the amendment would require employers with fewer than 50 retail employees to provide workplace violence training upon hiring and every two years thereafter (instead of annually); require that employers with 500 or more retail employees statewide provide to employees “silent response buttons” (identified as “panic buttons” in the current law) which must request immediate assistance from a security officer, manager or supervisor; and change the Mar. 3, 2025 effective date to Jun. 2, 2025 (though the “silent response button” requirement would still take effect January 1, 2027).

The NYSDOL is tasked with developing both a model written policy (which the NYSDOL will monitor every four years and update as needed) and model training. Covered employers should keep watch for the NYSDOL’s model policy and training, and either adopt them or implement a policy and training that at least meets the model’s standards by Mar. 3, 2025.  

In addition, the Labor Commissioner is required to adopt rules and regulations for the implementation of the law. Retail employers should monitor for this guidance as well.    

In advance of the effective date, train HR and managers / supervisors on the law’s requirements.  

Monitor Assembly Bill A1678 and other proposed legislation for amendments to the Retail Worker Safety Act.

(8) COVID-19 Sick Leave Sunsets in July | New York’s COVID-19 Paid Sick Leave Law will sunset on Jul. 31, 2025. The law entitles employees to paid COVID-19 leave when subject to a mandatory or precautionary order of quarantine or isolation due to COVID-19. After Jul. 31, employees will still be able to use other qualifying paid leave, including New York Paid Sick Leave, for COVID-19 related reasons. For more details, see our previous blog here. Update employment policies and practices in time to comply with the new laws and modify employee handbooks as necessary.

Train HR and managers / supervisors on the likely increase of employees using other types of paid sick leave for COVID-19 after Jul. 31.

(9) Starting in May, NYC Employers Must Provide Paid Lactation Breaks |New York City adopted Int 0892-2024, amending New York City’s existing lactation law in line with recently amended state law. Effective May 8, 2025, New York City’s existing lactation law–which requires that employers provide a lactation room, “reasonable” time to express breast milk, and a written lactation policy when employees begin employment, among other things–also mandates that employers:

(i) Provide 30 minutes of paid break time to express breast milk, and permit employees to use existing paid break time or meal time for time in excess of 30 minutes to express breast milk. Prior to the amendment, an employer was only required to provide “reasonable” break time for an employee under existing law, and the break time was not required to be paid.
(ii) Conspicuously post the company’s written policy regarding a lactation room at the employer’s place of business in an area accessible to employees–and electronically on the employer’s intranet, if one exists. This is in addition to the existing requirement to provide the policy to employees when they begin employment.

As a reminder, effective Jun. 19, 2024, New York State requires employers (for up to three years following the birth of a child) to:

(i) Provide paid break time of 30 minutes to allow an employee to express breast milk for the employee’s nursing child each time the employee reasonably needs to express breast milk;
(ii) Allow an employee to use existing paid break time or meal time in excess of 30 minutes to nurse; and
(iii) Inform employees about the right to take paid lactation breaks when they are hired, on an annual basis, and when the employee returns to work after the birth of a child.

For more details on the New York State law’s requirements, see our previous blog here.

Before May 8, update policies and practices to comply with the new law, and modify handbooks to include the changes.

Train HR and managers / supervisors on the new requirements, making sure they are aware that 30 minutes of break time will be paid and that employees may use existing paid break or meal time for additional time to express breast milk.

Monitor the New York City Commission on Human Rights lactation accommodations webpage for an updated model policy.      

(10) What We’re Watching:  Employers Will Be Required to Disclose AI-Related Layoffs | According to Governor Hochul’s Jan. 14, 2025 State of the State address and policy book, New York will be the first state to require employers to disclose AI-related job cuts.

At the Governor’s direction, the NYSDOL will require businesses submitting notices of worker layoffs to its Worker Adjustment and Retraining Notification (WARN) system to convey whether a layoff is related to a businesses’ use of AI. The NY WARN Act requires employers with 50 or more full time employees to provide at least 90 days’ notice if an employer plans to implement certain facilities closings, relocations, reductions in work, or layoffs.

Employers should monitor for developments and details. It is expected that Governor Hochul will issue an Executive Order in the coming days to implement this change.