Pursuant to its mandate to implement the new anti-sexual
harassment training requirements under the
Stop Sexual Harassment Act (the
"Act"), the New York City Commission on Human Rights
("Commission") just released FAQs clarifying various aspects
of the Act's training mandates. Most notably, the FAQs address
how an employer should determine whether it is covered by the
training requirement, as well as a covered employer's
obligations with regard to training independent contractors. The
training mandate becomes effective on April 1, 2019.
The Act requires employers with 15 or more employees to provide
annual, interactive training to all employees who work more than 80
hours in a calendar year and work for at least 90 days. In
determining whether it meets the 15-employee threshold, the FAQs
instruct employers to determine the number of employees they
employed "at any point within the prior calendar year."
In making this assessment, employers must count
