With the recent passage of anti-harassment legislation at the state and city level, New York employers face a series of deadlines for compliance in 2018 and 2019. This advisory presents a timeline of significant dates and details. Employers should note that the following is accurate as of April 17, 2019, and reflects information contained in guidance published by the State on October 1, 2018 and the City on April 1, 2019.

October 9, 2018

Action Required

Applicable Law

Adopt a sexual harassment prevention policy compliant with State law.

More information on State-mandated components of anti-harassment policies is available here.        

The New York State Division of Human Rights published guidance regarding the contents of employers’ revised anti-harassment policies.

New York State Budget Bill for FY 2019

Implement plan for compliance with New York State annual sexual harassment training requirements.

According the State’s FAQs, the first annual training requirement must be satisfied by October 9, 2019.

Click here and here for more information on training requirements under New York State law.

New York State Budget Bill for FY 2019

April 1, 2019

Action Required

Applicable Law

Implement plan for compliance with New York City annual sexual harassment prevention training requirements.

Training should take place as soon as possible after date of hire, and annually thereafter.

New hires who received training from a prior employer during same “training cycle” need not be re-trained by the new employer.        

Click here for our client update on anti-harassment training requirements under New York City law, and here for the City’s FAQs on the training requirements.

New York City Human Rights Law

December 31, 2019

Action Required

Applicable Law

Deadline for completing sexual harassment training compliant with requirements of New York City law for the 2019 “training cycle.”

Click here for our client update on anti-harassment training requirements under New York City law, and here for the City’s FAQs on the training requirements.

New York City Human Rights Law

For ease of administration, once all new hires have received the required training, New York City employers may choose to conduct a single set of annual harassment prevention training sessions which satisfy the requirements of both state and city laws.

DWT attorneys are available to help employers ensure compliance with these policy and training requirements.