Federal Contractors Face New Pay Transparency Rules in NY

If your business holds federal contracts, there's a new layer of pay transparency rules you need to know about. The Department of Labor just implemented stricter wage disclosure requirements for federal contractors, and with New York's own pay transparency laws already in effect, you're now juggling multiple sets of rules that don't always align perfectly.

What Changed

Starting this month, federal contractors must include salary ranges in all job postings and provide detailed compensation data to employees upon request. The new rules apply to any business with federal contracts worth $50,000 or more annually. According to the DOL, this expands beyond the previous requirements that only covered certain demographic reporting. Companies now must disclose not just base salary ranges, but also bonus structures, benefits values, and advancement opportunities in writing when requested by current employees.

Who This Affects

This hits a lot more NY businesses than you might think. Any company with federal contracts - from IT services and consulting firms to construction companies working on federal projects - now falls under these rules. In the NYC metro area especially, many mid-sized businesses have federal contracts without realizing they're now subject to federal contractor regulations. If you're a contractor, subcontractor, or vendor to federal agencies, these rules apply regardless of your company size.

What You Need to Do

• Audit all current job postings to ensure they include federal-compliant salary ranges by February 1st
• Create a process for responding to employee compensation inquiries within the required 30-day timeframe
• Train HR staff on the differences between federal and New York state disclosure requirements
• Update employee handbooks to reflect both sets of transparency obligations
• Review your federal contract language to understand which specific provisions apply to your business

The NY Angle

Here's where it gets tricky for New York businesses. The state's pay transparency law requires salary ranges in job postings, but the federal rules for contractors are more detailed. You might find yourself posting salary ranges that meet New York's requirements but fall short of federal standards, or vice versa. New York's law covers businesses with four or more employees, while the federal contractor rules kick in at the $50,000 contract threshold regardless of employee count. We've seen situations where companies need different posting formats for the same role depending on whether it's funded by federal contract dollars. The safest approach? Meet the stricter standard across all postings. We covered similar compliance challenges with ERISA penalty increases that also created layered federal-state requirements.

Need help navigating this? Benton Oakfield's compliance team works with businesses like yours every day. We can review your current setup and make sure you're covered. Reach out - it's what we do.

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