Sexual Harassment Policy, Training and Notice Requirements for New York Employers

Every employer in New York State, whatever its size, must have a written sexual harassment prevention policy, train all employees every year, and hand out a notice at hiring and at each training.⁠^[1][3][8] New York City adds its own layer: annual training with record-keeping for employers with 15 or more employees, a poster that every employer must display, and an information sheet that employers hand out at hire.⁠^[5][9][6] This page sets out each duty, who it applies to, and what an employee can look for.

State and City requirements side by side

Requirement	New York State (Labor Law § 201-g)	New York City (Admin. Code § 8-107(29), (30))
Which employers	Every employer; no minimum number of employees.⁠[2]	Training: employers with 15 or more employees. Poster: every employer. Information sheet: "employers," with no minimum stated in that subdivision.⁠[5][6]
Written policy	Required: the State model policy or one that equals or exceeds its minimum standards.⁠[1]	The City training must cover any internal complaint process available to employees through their employer.⁠[10]
Training	Annual and interactive, for all employees.⁠[3][4]	Annual and interactive, for all employees employed in the City, including supervisors and managers.⁠[5]
New hires	No set time; the State encourages training as soon as possible.⁠[11]	Required after 90 days of initial hire for those working more than 80 hours in a calendar year.⁠[12]
Records	No signed acknowledgment is required; keeping acknowledgments and training records is encouraged.⁠[13]	Training records, including a signed acknowledgment, kept for at least three years.⁠[9]
Notices	A written notice with the policy and the training information, at hiring and at every annual training.⁠[8]	A Commission-designed poster in English and Spanish, and an information sheet at hire.⁠[6]

Under federal Title VII, an employer's reasonable care to prevent and promptly correct harassment is one element of an affirmative defense to a supervisor's harassment that did not end in a tangible employment action.⁠^[14] The duties on this page come from New York State and New York City law.

The written policy (New York State)

Under Labor Law § 201-g, every employer must adopt the State's model sexual harassment prevention policy or establish its own policy that equals or exceeds the model's minimum standards, and must provide it to all employees in writing.⁠^[1] The model policy is published by the Department of Labor with the Division of Human Rights; as of October 2026 the version posted is marked "2023 version."⁠^[15]

The statute lists what the State model policy contains, which sets the floor for an employer's own policy:⁠^[16]

1. a statement prohibiting sexual harassment, with examples;⁠^[16]
2. information on the federal and State laws on sexual harassment and the remedies available, with a note that local laws may also apply;⁠^[16]
3. a standard complaint form;⁠^[16]
4. a procedure for the timely and confidential investigation of complaints that ensures due process for all parties;⁠^[16]
5. information on employees' rights of redress and all available forums for bringing complaints administratively and in court;⁠^[16]
6. a clear statement that sexual harassment is employee misconduct and that sanctions will be enforced against harassers and against supervisors and managers who knowingly allow it to continue;⁠^[16]
7. a clear statement that retaliation against people who complain, testify or assist in a proceeding is unlawful.⁠^[16]

The State model policy itself says no section should be omitted, although employers are encouraged to tailor it.⁠^[15] State law also requires the Department of Labor and the Division of Human Rights to evaluate the model policy every four years, beginning in 2022.⁠^[17] For a section-by-section reading, see inside New York State's model policy.

Annual interactive training (New York State)

Every employer must provide sexual harassment prevention training to all employees on an annual basis, using the State's model training or a program that equals or exceeds it.⁠^[3] Under the statute the training must be interactive and include an explanation of sexual harassment, examples of unlawful conduct, the federal and State laws and remedies, and employees' rights of redress and available forums; it must also address conduct by supervisors and their additional responsibilities.⁠^[4]

The State's published guidance fills in the practical details:

• Who is trained. All workers regardless of immigration status, including exempt and non-exempt employees and part-time, seasonal and temporary workers.⁠^[18]
• How often. At least once per year, measured by calendar year, the anniversary of each employee's start date, or any other date the employer chooses; there is no minimum number of hours.⁠^[19]
• What "interactive" means. Online training is acceptable if interactive; watching a video or reading a document with no feedback mechanism is not.⁠^[20]
• Pay. The State says training time generally counts as regular work hours under the federal regulations.⁠^[21]
• Out-of-state staff. Only employees who work or will work in New York State need the training, but someone who works a portion of their time in New York must be trained even if based elsewhere.⁠^[22]
• Contractors. The State says employers are not required to give the policy or training to independent contractors, vendors or consultants, but can be liable for those workers' actions in the workplace.⁠^[23]

The notice at hiring and at each training (New York State)

At the time of hiring and at every annual training, every employer must give each employee a written notice containing the employer's sexual harassment prevention policy and the information presented at its training.⁠^[8] The notice must be in English and in the language the employee identifies as their primary language.⁠^[8]

The language duty has a limit. If the employee's primary language is one for which the State has not published a template, the employer complies by providing an English-language notice, and an employer is not penalized for errors in the State's non-English templates.⁠^[24] The State's guidance says the notice may be delivered in print or digitally, for example by email, and must link to or include the policy and the training materials.⁠^[25]

What New York City adds

Training. Under the New York City Human Rights Law (NYCHRL), employers with 15 or more employees must conduct interactive anti-sexual harassment training every year for all employees employed in the City, including supervisors and managers.⁠^[5] The NYC Commission on Human Rights counts independent contractors and employees based outside the City toward the 15, and says the duty also applies to an employer of one or more domestic workers.⁠^[26] Government employers are outside the City training rule.⁠^[27]

The City training must cover a list of topics set by the Administrative Code, including the employer's internal complaint process, the complaint processes of the Commission, the State Division of Human Rights and the EEOC, the ban on retaliation, bystander intervention, and the specific responsibilities of supervisors and managers.⁠^[10] Employers must keep a record of all trainings, including a signed employee acknowledgment that may be electronic, for at least three years.⁠^[9] An employee who has been trained at one employer within the training cycle does not need to be trained again at another employer until the next cycle.⁠^[28]

One training for both rules. The Commission offers a free online training, about 45 minutes long, that it says satisfies both the State and City training requirements, as long as the employer also tells employees about its own internal complaint process.⁠^[29]

Poster and information sheet. The City's poster and information-sheet duties are in a different subdivision from the training rule, and that subdivision states no 15-employee threshold.⁠^[6] The Administrative Code requires every employer to display the Commission's anti-sexual harassment rights and responsibilities poster, in English and Spanish, in breakrooms or other common areas where employees gather.⁠^[6][30] Employers must also give each new employee the Commission's information sheet on sexual harassment at the time of hire; it may be included in an employee handbook.⁠^[31]

Related State duties

• Division of Human Rights notice. A State regulation requires employers subject to the State Human Rights Law to post the notices furnished by the Division, conspicuously, in easily accessible and well-lighted places customarily frequented by employees and applicants.⁠^[32]
• Hotline information. State law directs the Division of Human Rights to work with the Department of Labor so that information on the State's workplace sexual harassment hotline is included in materials employers must post or provide to employees about sexual harassment.⁠^[33]
• State contractors. Every competitive bid to the State must contain a statement, under penalty of perjury, that the bidder has a written sexual harassment prevention policy and provides annual training meeting at least the requirements of Labor Law § 201-g.⁠^[34]

What compliance does and does not do

Having a policy and training in place is a legal duty; it does not by itself defeat a claim. The State's model policy says on its first page that adopting it does not constitute a defense to charges of unlawful sexual harassment, and that each claim is decided on its facts, including whether an effective anti-harassment policy and procedure existed.⁠^[7] Under the State Human Rights Law, the fact that a person did not complain to the employer is not determinative of whether the employer is liable.⁠^[35] The comparison across the three layers is in what employers argue: the common defenses.

On enforcement of the State policy and training rule itself, the State tells employees that they can file a complaint with the New York State Department of Labor, which can contact the employer and educate it on the requirements of the law.⁠^[36] In New York City, the training records must be made available to the Commission for inspection on request.⁠^[37]

What an employee can check for

If you want to know whether your workplace is meeting these rules, these are the things the laws above call for:

• A written sexual harassment prevention policy given to you in writing, with a complaint form.⁠^[1][16]
• A notice with the policy and training information when you were hired and again at each annual training, in English and, where the State has a template, your primary language.⁠^[8][24]
• Training once a year that lets you ask questions or give feedback.⁠^[19][20]
• In New York City: the NYC Commission on Human Rights poster in English and Spanish in a common area, and the information sheet at hire.⁠^[6]

Managers and owners will find a broader checklist in for managers and small employers, and small workplaces are covered in small businesses and family-owned employers. If you are deciding whether to use your employer's complaint process, see how to report harassment to your employer, do I have to report to HR first? and what happens in an HR investigation.