As of January 1, 2026, California’s AB 692 drastically limits the use of “Stay-or-Pay” or Training Repayment Assistance Programs (TRAP) agreements—contracts that require employees to reimburse expenses like training or relocation upon early departure. Employers need to act now to understand the law and adjust their strategies.
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Prep Now For the California Workplace Know Your Rights Act: Action Required by February 1
By February 1, 2026, employers must give California employees a notice explaining their constitutional rights when interacting with law enforcement at the workplace, their immigration rights and protections, their rights to workers’ compensation benefits, their rights to organize or engaged in concerted activity, and other “new legal developments.” And by March 30, 2026, employers must…
From New York City to the European Union: Pay Equity Developments Multinational Employers Need to Know in 2026
On December 4, the New York City Council voted to override Mayor Eric Adams’ vetoes of two bills requiring annual pay reporting and pay analyses. These bills—requiring private employers to report pay data by race and gender and mandating a city-led pay equity study—are emblematic of a nationwide trend toward greater scrutiny of compensation practices.
As we dive into the new year, here’s what employers need to know about the new NYC reporting requirements, recent changes to pay data reporting requirements in California, Illinois and Massachusetts, and the upcoming EU Pay Transparency Directive.
While pay reporting laws focus on accountability and seek to enable regulatory oversight and systemic analysis of pay equity across organizations, pay transparency regulations emphasize visibility, aiming to enable applicants and employees to make informed decisions and reduce information asymmetry. A round-up of recent pay transparency developments is included.
New NYC Pay Data Reporting Requirements
New law (Int 0982-A) requires employers with 200 or more employees inclusive of full-time, part-time and temporary employees) in the city to file annual reports detailing employee race or ethnicity and gender information across certain job categories and different pay ranges. Although the pay-reporting requirements take effect immediately, employers are not required to submit information until the city creates a process for doing so, which we may not see until as late as 2028.
- Reporting Details: The new reporting requirements are similar to requirements imposed by the Equal Employment Opportunity Commission (and similar to reporting requirements in California and Illinois). In 2017 and 2018, the EEOC previously called for employers to submit employees’ W-2 income information broken down by gender, race/ethnicity and job category (i.e., component 2 EEO-1 data), though the rules were rescinded during the first Trump administration. The new law requires the city agency overseeing this new initiative to include this component 2 EEO-1 data in the reporting requirements, but may also request additional data, such as information about employee gender identity or other demographics. Employers will not need to provide an employee’s personal information as part of the reports, but they will have the option to submit written remarks to provide explanations or context for the data in their submission. Additionally, employers may furnish data anonymously, but will required to submit a signed statement confirming that they provided accurate pay data.
Pre-emption by Executive Order: Trump Order Moves to Block State AI Laws
On December 11, 2025, President Trump signed an Executive Order on “Ensuring A National Policy Framework For Artificial Intelligence” (the “Order”). The Order represents the Administration’s latest and most pointed attempt to stop and reverse the wave of state AI legislation that has emerged over the preceding year, which the Order asserts “creates a patchwork of 50 different regulatory regimes.” The Order raises the political stakes regarding state AI laws and creates uncertainty in the form of anticipated litigation, but does not instantly remove current or impending state AI law obligations for companies developing or deploying AI.Continue Reading Pre-emption by Executive Order: Trump Order Moves to Block State AI Laws
Future-Focused: Our 2026 Checklist to Shift California Employers Into High Gear
As California continues to set the pace for employment law regulation, 2026 looks to be another high-speed race filled with sharp turns and new obstacles. From restrictions on repayment agreements and expanded Cal WARN notice requirements to stricter pay equity rules, and much more, California employers are entering a compliance race where every second counts.
Register Now: 2026 California Employer Update Webinar | Navigating Change with Precision
Fast Track to 2026: A 75-Minute Must-Attend Webinar for In-House Counsel
The legal landscape impacting California employers is evolving at breakneck speed. As we race toward 2026, employers need to stay agile, informed, and ready to shift gears. This high-impact session will cover the most pressing workplace trends, risks, and regulatory changes ahead for California…
New California Requirements on AI, Risk Assessments, and Cybersecurity (Webinar, September 30)
CPPA Adopts Expanded Regulations
Please join us for our next virtual session to discuss the newly adopted CCPA regulations—on September 30 from 12 to 1pm Pacific. In this session, our interdisciplinary team will discuss what the new regulations cover and what companies can do now to comply.
Click here to register.
CLE will be offered.
Navigating Labor’s Response to AI: Proactive Strategies for Multinational Employers Across the Atlantic
As AI adoption accelerates across workplaces, labor organizations around the world are beginning to take notice—and action. The current regulatory focus in the US centers on state-specific laws like those in California, Illinois, Colorado and New York City, but the labor implications of AI are quickly becoming a front-line issue for unions, potentially signaling a new wave of collective bargaining considerations. Similarly, in Europe the deployment of certain AI tools within the organization may trigger information, consultation, and—in some European countries—negotiation obligations. AI tools may only be introduced once the process is completed.
This marks an important inflection point for employers: engaging with employee representatives on AI strategy early can help anticipate employee concerns and reduce friction as new technologies are adopted. Here, we explore how AI is emerging as a key topic in labor relations in the US and Europe and offer practical guidance for employers navigating the evolving intersection of AI, employment law, and collective engagement.
Efforts in the US to Regulate AI’s Impact on Workers
There is no specific US federal law regulating AI in the workplace. An emerging patchwork of state and local legislation (e.g. in Colorado, Illinois and New York City) address the potential for bias and discrimination in AI-based tools—but do not focus on preventing displacement of employees. In March, New York became the first state to require businesses to disclose AI-related mass layoffs, indicating a growing expectation that employers are transparent about AI’s impact on workers.[1]
Some unions have begun negotiating their own safeguards to address growing concerns about the impact that AI may have on union jobs. For example, in 2023, the Las Vegas Culinary Workers negotiated a collective bargaining agreement with major casinos requiring that the union be provided advance notice, and the opportunity to bargain over, AI implementation. The CBA also provides workers displaced by AI with severance pay, continued benefits, and recall rights.
Similarly, in 2023 both the Writers Guild of America (WGA) and Screen Actors Guild-American Federation of Television and Radio Artists (SAG-AFTRA) negotiated agreements with the Alliance of Motion Picture and Television Producers (AMPTP) that include safeguards against AI reducing or replacing writers and actors. WGA’s contract requires studios to meet semi-annually with the union to discuss current and future uses of generative AI—giving writers a formal channel to influence how AI is deployed in their industry. The SAG-AFTRA contract requires consent and compensation for use of digital replicas powered by AI.Continue Reading Navigating Labor’s Response to AI: Proactive Strategies for Multinational Employers Across the Atlantic
5 Key Considerations for Multinational Employers Mulling Return to Office
With nearly two-thirds of U.S. companies mandating formal return-to-work policies, employers may face challenges in enforcing RTO practices. Multinational employers should be aware of five key considerations and practical solutions to avoid potential roadblocks.
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Original article published in Law360.
Passage of Reintroduced California AI Bill Would Result In Onerous New Compliance Obligations For Covered Employers
Shortly after taking office, President Trump rescinded Biden’s Executive Order on Safe, Secure, and Trustworthy Artificial Intelligence. Biden’s Executive Order sought to regulate the development, deployment, and governance of artificial intelligence within the US, identifying security, privacy and discrimination as particular areas of concern. Trump signed his own executive order titled “Removing Barriers to American Leadership in Artificial Intelligence,” directing his advisers to coordinate with the heads of federal agencies and departments, among others, to develop an “action plan” to “sustain and enhance America’s global AI dominance” within 180 days.
While we wait to see if and how the federal government intends to combat potential algorithmic discrimination and bias in artificial intelligence platforms and systems, a patchwork of state and local laws is emerging. Colorado’s AI Act will soon require developers and deployers of high-risk AI systems to protect against algorithmic discrimination. Similarly, New York City’s Local Law 144 imposes strict requirements on employers that use automated employment decision tools, and Illinois’ H.B. 3773 prohibits employers from using AI to engage in unlawful discrimination in recruitment and other employment decisions and requires employers to notify applicants and employees of the use of AI in employment decisions. While well-intentioned, these regulations come with substantial new, and sometimes vague, obligations for covered employers.
California is likely to add to the patchwork of AI regulation in 2025 in two significant ways. First, California Assemblymember Rebecca Bauer-Kahan, Chair of the Assembly Privacy and Consumer Protection Committee, plans to reintroduce a bill to protect against algorithmic discrimination by imposing extensive risk mitigation measures on covered entities. Second, the California Privacy Protection Agency’s ongoing rulemaking under the California Consumer Privacy Act will likely result in regulations restricting the use of automated decision-making technology by imposing requirements to mitigate algorithmic discrimination.Continue Reading Passage of Reintroduced California AI Bill Would Result In Onerous New Compliance Obligations For Covered Employers