EMPLOYMENT LAW NEWS
Legislative Scoop: Key Potential Employment Laws from New York State
By Grant Larson, Compliance Paralegal
Employment Law and Compliance
Published October 13, 2026
This month’s Legislative Scoop reviews three New York bills covering severance agreements, wage change notices, and ghost job postings that stalled before the 2026 session ended but are likely to return in 2027.
Each month, GovDocs’ Employment Law and Compliance Team provides the scoop on key bills making their way through the legislative process. This month, we are looking at three New York bills in the final stage of that process. Each has passed both houses of the Legislature but has yet to be delivered to the governor for signature.
Key Takeaways
✓ Three New York employment bills are awaiting delivery to the governor for signature: S372-A/A6480-A (severance agreements), S2236-A/A2222-A (wage change notices), and S8877/A6292-A (ghost job postings).
✓ S372 would require a notice with severance agreements: employees must be told they have the right to consult an attorney, at least 21 days to review the agreement, seven days to revoke it after signing, and the option to sign before the review period ends on their own terms.
✓ S2236 would change the definition of wages: employers would have to disclose wage changes in writing, “wages” would include compensation not payable at the employer’s discretion, bonuses could be excluded only if employees are notified that payment is discretionary, and new penalties would apply for improper notice.
✓ S8877 would target “ghost jobs”: job advertisements would have to include, in bold capital letters, how quickly employers plan to fill the role and whether it is currently vacant. Advertisements must come down within two weeks of the role being filled.
New York No Severance Ultimatums Act (S372-A/A6480-A):
Severance Agreement Notice Requirements
The first bill we will highlight this month is S372-A. This bill is known as the “No Severance Ultimatums Act,” and if signed, it would require an employer to provide a notice to an employee being presented with a severance agreement. The contents of the notice must include that an employee has the right to consult an attorney, the right to review the agreement for at least 21 days, the right to revoke the agreement within seven days after it was signed before it becomes enforceable, and that an employee can sign it before the consideration period if it happens on the employee’s terms. This means that shortening the consideration period must be a knowing, voluntary decision not induced by fraud, misrepresentation, a threat to change the review period, or different terms.
New York Wage Payment Integrity Act (S2236-A/A2222-A):
Written Notice of Wage Changes
The next bill is S2236-A, titled the “Wage Payment Integrity Act”. This bill would require an employer to disclose in writing to an employee any changes to their wages. S2236 would change the definition of “wages” to include compensation that’s not payable at the employer’s discretion. The bill would also clarify that a bonus can be excluded from the definition of wages listed above only if the employee is notified that an employer can determine whether the bonus will be paid. The proposed bill would also add penalties for employers who do not give an employee proper notice under the Act. This is a bill that we will be monitoring closely at GovDocs when the legislative session resumes in New York.
New York Ghost Jobs Bill (S8877/A6292-A):
Job Posting Disclosure and Removal Requirements
The final bill covered this month is S8877, which is informally known as the “Ghost Jobs” bill. This bill, if enacted, would apply to employers with at least 100 employees and third-party job posting entities, and require job advertisements to include language detailing how quickly the employer plans to fill the position and whether the position is currently vacant. This mandatory language would need to be in bold and in capital letters.
This bill also includes a few requirements for when a position is filled by an employer. When a position is filled, an employer must remove all job postings within two weeks of the position being filled. Additionally, if using a third-party job board, the employer must also provide notice to the company within two weeks. Any third-party job board has two weeks to remove the job posting from its website when it should reasonably know that a job has been filled. In practice, this would mean it has two weeks after the date listed on the original job notice, or two weeks after receiving notice from an employer. Employers and third-party job posting entities that violate this section would face a fine of $2,500 for each publication of a noncompliant job advertisement. If the violation is not corrected within 30 days, the fine would increase to $5,000 and double for each additional 30 days of noncompliance.
Conclusion
All three of the bills discussed passed both the Senate and the Assembly and are awaiting delivery to the governor, who may sign or veto them. If signed, each bill would take effect immediately, leaving employers no transition period. Employers with New York operations may want to review their severance agreement templates, wage change notice practices, and job advertisement processes now to be prepared if the governor signs them.
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This Employment Law News blog is intended for market awareness only, it is not to be used for legal advice or counsel.
