New York employers have two important compliance dates this month, July 15 and July 23. Here's what management needs to know--plus an important reminder on a law that's already in effect.
JULY 15 DEADLINE — NYS SECURE CHOICE (10–14 EMPLOYEES)
As we shared in March, July 15, 2026 was the final compliance deadline under the New York Secure Choice program.
If your business has 10–14 employees, has been in operation at least two years, and does not already offer a qualified retirement plan (401(k), 403(b), SEP, SIMPLE, or similar), you must be registered through the state portal and facilitate payroll deductions.
If you do already offer a qualified plan, you still need to log into the portal and certify your exemption. This step is easy to overlook, but it is not optional.
Employers with 15 or more employees should already be registered or certified; if you missed an earlier deadline, don't wait — get compliant now rather than risk enforcement.
DO NOW: If you have 10–14 employees and haven't registered or certified an exemption, do it today here.
JULY 23 DEADLINE — NYC ESSTA EXPANDS AGAIN
New York City's Earned Safe and Sick Time Act (ESSTA) is expanding again, effective July 23, 2026.
The new rules:
- Define "protected time off" and broaden the permissible uses of ESST, including caregiving, legal and housing matters, public disasters, and workplace violence;
- Confirm the requirement (added earlier this year) that employers front-load at least 32 hours of unpaid safe/sick time annually, immediately available at hire and at the start of each calendar year; and
- Clarify paid prenatal leave obligations, notice requirements, and penalties for noncompliance.
If your NYC handbook and leave-tracking systems haven't been updated since February's ESSTA amendments, this is the moment to close that gap. The City is not slowing down on enforcement in this area.
DO NOW: NYC employers should review handbooks, leave policies, and payroll/timekeeping systems to ensure ESSTA compliance before July 23.
REMINDER — CREDIT HISTORY BAN NOW IN EFFECT
Since April 18, 2026, most New York employers may no longer request or use an applicant's or employee's consumer credit history — including credit reports, scores, or account information — in hiring, compensation, or promotion decisions.
If your intake forms, background check vendor instructions, or manager training haven't been scrubbed of credit history references, this is a good time to do it.
Narrow exceptions exist (certain law-enforcement and security clearance positions, and situations where credit checks are independently required by law), so if you think an exception might apply to your business, it's worth confirming before relying on it.
As always, these are general updates and do not substitute advice on your specific situation. If you'd like help reviewing your handbook, leave policies, or Secure Choice status, contact us.