As we mentioned in a previous blog post here, on September 19, 2012, New Jersey Governor Chris Christie signed into law Bill A2647, which requires an employer with fifty or more employees to provide written notice and post notices that detail an employee’s right “to be free of gender inequity or bias in pay, compensation, benefits or other terms or conditions of employment” under the New Jersey Law Against Discrimination, Title VII of the Civil Rights Act of 1964, and the Equal Pay Act of 1963.
The New Jersey Department of Labor (“NJDOL”) has issued proposed rules providing guidance about the new law, along with a sample proposed notice for posting and distribution to employees. The rules and notice are available here.
Importantly, in the proposed rules, the NJDOL clarified a significant point of confusion regarding to which entities the posting and notification requirements applied. Per the proposed rules, the law applies broadly to New Jersey employers with 50 or more employees regardless of whether those employees work inside or outside of New Jersey.
Although this new law went into effect on November 19, 2012, employers are not obligated to comply with the notice posting requirement until a final form notice and rules are issued. The comment period for the proposed rules ended on March 23, 2013. The NJDOL is expected to release a final form of the notification this summer.
The NJDOL will be posting regular updates on its website as to the status of the rulemaking.