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why does not having any nyc employees yet exempt them if they are hiring nyc-based people?


The official explanation* of the law reads:

> All employers that have four or more employees or one or more domestic workers are covered by the NYCHRL, including this new provision of the law. As with other provisions of the NYCHRL, owners and individual employers count towards the four employees. The four employees do not need to work in the same location, and they do not need to all work in New York City. As long as one of the employees works in New York City, the workplace is covered.

I don't have a law degree, but I read that as the law only applies if the company currently has at least four employees, one of which "works in New York City." If a company intends to hire someone in NYC but has no employees there yet the law wouldn't apply to them yet, probably because NYC wouldn't have jurisdiction without a nexus in the city.

* https://www1.nyc.gov/assets/cchr/downloads/pdf/publications/...




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