February 24, 2026
New Jersey Governor Issues 90-Day Regulatory Freeze – What Employers Should Know
On January 23, 2026, New Jersey Governor Mikie Sherrill issued Executive Order No. 7, which places a 90-day pause on most new and pending state regulations, including those issued by agencies that affect employment practices, such as the New Jersey Department of Labor and Workforce Development.
Below is a summary of what this means for New Jersey employers.
What the Executive Order Does
For 90 days, State agencies generally may not propose or adopt new regulations. In addition, many rules that were proposed but not yet finalized must be paused or withdrawn unless the Governor specifically approves them.
The Governor’s Office will review pending regulations and may allow certain rules to move forward if delaying them would:
- Affect public health, safety, or welfare;
- Interfere with essential agency operations;
- Conflict with court orders or legal deadlines; or
- Risk the loss of federal funding.
What Does Not Change
This Executive Order does not change current employment law. Employers should be aware that:
- All existing employment laws and regulations remain fully in effect
- Agency investigations, audits, and enforcement actions will continue
- Employers must continue complying with current wage and hour, leave, discrimination, and worker classification requirements
- The Executive Order does not create new legal rights or defenses for employers
Proposed Employment Rules Now on Hold
Any employment-related rules that were proposed but not yet adopted, particularly those introduced within the last 12 to 18 months, are now on hold unless the Governor grants an exception.
This includes proposed New Jersey Department of Labor rules addressing topics such as:
- Independent contractor classification
- Tipped wage practices
- Recordkeeping requirements
- Joint employment standards
- Pay transparency implementation details
The freeze may also delay technical regulations that would expand employer reporting or workplace posting requirements.
What This Means for Employers
As a practical matter:
- Employers may see a delay in new compliance obligations that were expected to take effect soon
- Businesses that were preparing to make changes based only on proposed rules may have some short-term flexibility to pause those efforts
- Uncertainty is likely to continue until the review process is complete and agencies clarify which rules, if any, will move forward
For employers currently involved in investigations or disputes, agencies are expected to continue relying on existing laws and regulations rather than new or pending rules.
Recommended Next Steps
We recommend that employers:
- Continue complying fully with all existing New Jersey employment laws
- Avoid making costly operational changes based solely on proposed regulations unless advised otherwise
- Monitor developments over the next 90 days
- Consult counsel before making compliance decisions that rely on the regulatory freeze
If you have any questions about your rights and obligations under federal, New York or New Jersey employment laws, please reach out to Chaim Book at cbook@booklawllp.com, Sheryl Galler at sgaller@booklawllp.com, Rebecca Nathanson at rnathanson@booklawllp.com, or Andrew Heighington at aheighington@booklawllp.com.
