SEPTEMBER EDITION

Your Compliance Questions, Answered: Electronic Display of Unemployment Insurance Posters in GA, CT’s Pay Transparency Update, and NY’s New Personnel Records Act

Christina GovDocsBy Christina Everling, GovDocs Attorney
Employment Law and Compliance
September 22, 2026

Q&A September Edition: Your Compliance Questions, Answered: Electronic Display of Unemployment Insurance Posters in GA, CT’s Pay Transparency Update, and NY’s New Personnel Records Act

GovDocs’ Employment Law & Compliance Team breaks down New York’s new Access to Personnel Records Act, effective Nov. 8, 2026. This edition covers what qualifies as a “personnel record,” the five day and ten day notice deadlines employers must meet, and why a pending Chapter Amendment means the law’s current text may not be its final form.

Staying compliant in today’s rapidly evolving employment law landscape often raises more questions than answers. Each month, Christina Everling, GovDocs’ Attorney on the Employment Law & Compliance Team, tackles the most–asked employment law compliance questions by employers across the country. 

 

Can Georgia Employers Display Unemployment Insurance Posters Electronically? 

On June 15, 2026, Georgia’s Department of Labor (GDOL) released a Notice of Intended Action, proposing amendments to 11 rules regarding its Employment Security Law in an order to “modernize how GDOL serves Georgia’s employers.” The revised rules went into effect on Aug. 9, 2026. Among those revisions, Rule 300-2-7-.15, Display of Posters for Information of Employees, was amended to include options for electronic display of unemployment insurance posters in specific circumstances. 

The Uneventful History of Rule 300-2-7-.15 

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Rule 300-2-7-.15, which requires employers to post and maintain printed information regarding employee rights under the Employment Security Law in readily accessible places, was originally adopted in 1998. It remained unchanged for 28 years until the 2026 amendment. 

What Changed? 

According to GDOL, “[t]his rule is completely re-written in an effort to recognize the reality of the modern virtual workplace.” In fact, GDOL took the two-paragraph rule and expanded it into nine paragraphs that include: 

  1. A purpose 
  2. Definitions 
  3. A notice requirement 
  4. A physical posting requirement 
  5. Electronic posting as a supplement 
  6. Electronic posting as a substitute 
  7. A safe harbor for hire-time delivery to remote employees 
  8. Employers excluded from the posting requirement 
  9. Recordkeeping 

Under the revised rule, unemployment insurance information in the form of a printed statement, poster, or notice issued by the Commissioner or the Department is considered to be a “Required Notice.” 

Electronic Posting as a Substitute for Physical Posting

The Required Notice must still be posted in a conspicuous place (e.g., near a time clock, in a break room, or in another location customarily used to display employee notices) at traditional worksites. However, the amendment accommodates “modern and remote work arrangements.” As a result, the updated rule encourages employers to also provide supplemental electronic posting of the Required Notice through the employer’s intranet, employee self-service portal, shared drive, or comparable platform. As a default, electronic posting is in addition to the physical posting and does not replace it. 

Only in limited circumstances does the rule allow for electronic posting as a substitute for physical posting:  

  1. When the employer has no worksite that is a physical location owned, leased, or controlled by the employer where at least one employee regularly performs work and all of the employer’s Georgia employees are remote employees; or 
  2. Where the Required Notice is being provided to remote employees who do not regularly report to a worksite. 

In the second scenario, the Required Notice must still be posted at the worksite where non-remote employees report. When employers are substituting electronic posting for physical posting in either of the situations above, employers must: 

  1. Ensure the Required Notice is continuously available and not behind a one-time prompt or transient message; 
  2. Affirmatively inform each affected employee of the electronic location of the Required Notice and how to access it; and 
  3. Ensure all affected employees are able to access the Required Notice readily, without having to request permission. 

Hire-Time Delivery Safe Harbor 

In lieu of the substitute-posting obligations mentioned above, employers may satisfy Rule 300-2-7-.15 for a remote employee if, at or before the employee starts work, the employer: 

  1. Provides the Required Notice to the employee electronically or in hard copy with the employee’s onboarding materials; 
  2. Obtains written or electronic acknowledgment of receipt, or keeps a system record showing delivery; and 
  3. Keeps the Required Notice somewhere accessible to the employee and notifies the employee of any updates made to the Required Notice within 30 days after the update is published. 

If employers rely on electronic posting or the hire-time safe harbor, they should document compliance with a screenshot of the posting location, a system delivery log, employee acknowledgment of receipt, or dated notifications to employees of the location or update of the Required Notice. 

Electronic Postings in Other States 

A handful of states permit electronically displaying certain labor law postings. Like in Georgia, some laws are narrowly tailored to a single poster. For example, New Jersey’s Law Against Discrimination posting may be displayed on an employer’s internet or intranet site in lieu of physical display if all employees have access to such a site and the employer customarily posts notices to affected employees there. Other states, such as Ohio, allow the digital display of multiple posters, including its Child Labor Law poster, Minimum Wage poster, Fair Employment Practices Law poster, Workers’ Compensation poster, and Rebuttable Presumption Law poster. 

Electronic posting replaces physical posting only in narrow circumstances, so Georgia employers should treat physical posting as the default and confirm eligibility before relying on an electronic substitute. GovDocs covers both types of posting formats: our Labor Law Poster Program supplies your worksites, and the Intranet Poster Program serves your remote and hybrid employees.

 

What is Changing in Connecticut’s Pay Transparency Statute? 

In May 2026, Connecticut passed HB 5003, a broad workforce bill covering numerous employment-law-related topics. GovDocs previously highlighted the new requirement for employers to provide notice of employees’ right to reasonable accommodations that goes into effect on Oct. 1, 2026. Also taking effect on this date is an expansion of Connecticut’s pay transparency statute. 

Connecticut’s Current Pay Transparency Law 

Under Connecticut’s existing pay transparency law, there is no requirement for employers to include pay ranges in job advertisements. However, employers must provide employees with the pay range for the position in which the employee is currently employed at the time of hire, when there is a change in the employee’s position, and upon the employee’s first request for a pay range for their position. Employers are also required to provide salary range information to applicants upon their request or by the time they extend an offer of compensation—whichever is earlier. 

The current law also prohibits employers from inquiring about a prospective employee’s wage and salary history unless the individual voluntarily discloses such information. Furthermore, employers cannot prevent or retaliate against employees for discussing wages with other employees. 

What is New? 

HB 5003 expands the pay disclosure requirements for applicants and current employees to include a general description of benefits to be offered with the position, in addition to the wage range of the position. “Benefits” include health insurance benefits, retirement benefits, fringe benefits, paid leave, and any other compensation other than wages to be offered with a position. For applicants, pay and benefit information was previously required at the earlier of the applicant’s request or at or before an offer of compensation is made. Now, that second trigger includes any discussion of compensation, whether or not an offer is made. 

New provisions in the bill add a pay transparency requirement for job advertisements, along with anti-retaliation and anti-discrimination protections. Starting on Oct. 1, 2026, employers must include the wage range and a description of benefits for each position in internal or public job advertisements. Employers must not retaliate or discriminate against applicants or employees for exercising their rights regarding wage and benefit information. Retaliation or discrimination includes refusal to interview, hire, or promote someone, and termination of employment. 

Impacts of the Pay Transparency Amendment 

The pay transparency provisions apply to all Connecticut employers and to jobs performed in the state or where employees performing job duties outside of the state report directly to a supervisor or office located within Connecticut. Because the law reaches employees who report to a Connecticut supervisor or office from out of state, multistate employers should confirm which roles are covered before the Oct. 1, 2026, effective date and update advertisement templates accordingly.  

Need help managing pay transparency laws across your business locations? Visit GovDocs Minimum Wage. 

 

What Does New York’s New Access to Personnel Records Act Require? 

On Sept. 9, 2026, New York’s governor signed Senate Bill S3460 (Assembly companion A2107), the Access to Personnel Records Act, which takes effect on Nov. 8, 2026. 

New York joins a growing list of states that have enacted personnel records access laws. In fact, the bill’s sponsor memo expressly states that this statute is modeled on Massachusetts’ Personnel Record Law. 

New Employee Access Rights 

The purpose of this legislation is to provide workers with the opportunity to review their personnel records and the right to be notified when a negative report is filed against them. To that end, under this law, employers in both the public and private sectors must: 

  1. Provide a copy of an employee’s personnel record within five business days of a written request, at no cost to the employee; 
  2. Notify the employee within 10 days of placing information in the record that could negatively affect that employee’s qualification for employment, promotion, transfer, additional compensation, or disciplinary action; and 
  3. Allow the employee to submit a written statement disputing information in the record when the employer and employee cannot agree on a correction, which then becomes part of the record. 

These access rights apply to both current and former employees. The statute defines “personnel record” broadly to include employee information (e.g., name, address, and date of birth), job applications, resumes, performance evaluations, written warnings, disciplinary documentation, and compensation information. Employers may limit record review to twice in a calendar year, though a review triggered by the employer adding negative information does not count toward that limit. 

Recordkeeping

Employers must retain a complete personnel record, without deletions, for three years after an employee’s termination. If an employer chooses to keep a written personnel policy, the law requires that policy be “continuously maintained” at the office that handles personnel matters. The law also includes an anti-retaliation provision that specifically prohibits threatening to report an employee’s immigration status, or a family or household member’s status, in response to the employee exercising these rights. 

A Chapter Amendment is Expected 

Reports indicate that when the governor signed the bill, she identified “ambiguities” in the statutory language and reached an agreement with the Legislature on a Chapter Amendment to address them. The anticipated changes would clarify that employers are not required to create a personnel file or produce new documents beyond what they already maintain, and that “personnel record” only covers documents used for employment decisions. That amendment is expected during the legislative session beginning in Jan. 2027. Until then, the law applies as written, so employers should comply with the current text while monitoring for the amendment. 

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