February 24, 2026
Updates to the NYS Trapped at Work Act: What Employers Need to Know
As we previously reported, on December 19, 2025, New York State Governor Kathy Hochul signed into law the Trapped at Work Act. The Act, as signed, would prohibit New York employers from requiring workers, as a condition of employment, to agree to repay the costs of training and other benefits if the worker leaves employment before a specified time.
The Governor made clear that she expected the NYS legislature to limit and clarify the Act’s scope. The NYS legislature passed amendments to the Act on January 11, and Governor Hochul signed the amendments on February 13, 2026.
What changed?
Effective date: The effective date has been extended until December 19, 2026.
Narrowed Coverage: The Act will apply to employees, defined as “any person employed for hire by an employer in any employment,” not all workers.
Carve-out for Repayment Agreements Related to “Transferable Credential”: Employers may require employers to repay the costs of training that is required or advantageous for employment in the relevant industry, not only for the particular employer, and provided that the repayment agreement meets the criteria listed in the Act.
Enforcement Updates: The New York Department of Labor must consider certain factors when assessing penalties against employers who violate the Act.
The extended start date for the Act provides employers with time to review their employment, training and separation agreements to ensure that they comply with the new requirements. If you have any questions about the Act or your employment agreements or compensation arrangements, please reach out to Chaim Book at cbook@booklawllp.com, Sheryl Galler at sgaller@booklawllp.com, Rebecca Nathanson at rnathanson@booklawllp.com, or Charlotte Pramer at cpramer@booklawllp.com.
