NEW YORK TRAPPED AT WORK ACT: Status Update: February 2026

In late 2025, New York enacted the Trapped at Work Act, which restricts an employer’s ability to require repayment of sign-up bonuses, relocation allowances, tuition and education payments (often called “stay-or-pay” provisions).

The 2026 Amendments: Following significant feedback from the business community regarding the law’s unintended consequences, the Legislature passed Chapter Amendments in January 2026.

• Delayed Implementation: The full effective date of the Act has been stalled and is now expected to go into effect on December 19, 2026.
• Current Status: For the majority of 2026, the Act will likely not be in full effect, and employers remain generally free to place restrictions on these upfront payments until the revised law takes over in December. However, employers should use this “runway” to review and update their promissory notes to meet the new, narrower standards.