New York has no small-employer exemption to fall under.
Most small employers know the federal laws start at fifteen people and reasonably conclude that nothing applies below that. New York does not use that line. Labor Law 201-g reaches every employer in the state, and the state's own guidance confirms it down to a household employing a single nanny. If you have one employee in New York, you owe annual training and a written policy.
Every employer means every employer.
New York removed the headcount question entirely. There is no number to sit under, which means the usual small-business reasoning does not work here.
Under fifteen people is not the same as exempt.
The federal thresholds are what most owners have heard of: fifteen employees for Title VII, the ADA, and the Pregnant Workers Fairness Act, twenty for the ADEA. Those are real, and below them the federal half genuinely does not apply. New York's training mandate simply does not use headcount as a trigger, so it arrives at your first hire and stays.
The state has been unusually explicit about the bottom of the range. Its own published guidance confirms that a household employing one person as a nanny or housekeeper must adopt a prevention policy and provide annual training. If the rule reaches a single domestic employee, it reaches a six-person firm.
The other thing small employers miss is that this is two obligations, not one. The training is annual. The written policy is separate, and it must be handed to every employee at the time of hiring and again at every annual training. Employers who run training and stop there have completed half of what the statute asks.
What New York requires the training to cover
- Delivery that is genuinely interactive, not a document to read
- An explanation of sexual harassment consistent with state guidance
- Concrete examples of conduct that constitutes unlawful sexual harassment
- The federal and state statutory provisions, and the remedies available to victims
- Employees' rights of redress and all available forums for adjudicating complaints
- Conduct by supervisors, and the additional responsibilities supervisors carry
The full structure, scaled to your size
Our standard program with the scope matched to a small team. Nothing structural is missing; the volume is matched to a single state, and the training is built to what New York actually prescribes.
Training That Meets the State's Own Spec
Role-specific training built to the duration, cadence, and content the statute names, and documented to the individual with a date. A completion record that cannot be tied to a named employee on a named day is not much of a record.
Employee Reporting Hotline
A confidential channel by phone, email, or web that does not route through the owner or the one manager. In a small company the person an employee would normally report to is frequently the person they need to report about.
Manager Advisory Line
A number your manager or owner calls before acting, not after. The expensive mistakes in small companies are rarely the original incident. They are the termination, the schedule change, or the reply-all in the week that follows.
Quarterly Check-Ins
A confidential check-in with your team every quarter, so issues surface while they are still small enough to correct. It also builds a dated record showing you were looking, which an employer with no HR department otherwise cannot demonstrate.
Policy, Notice, and Documentation
The written policy, complaint procedure, and posting or distribution obligations the state imposes alongside training, plus the file structure to hold acknowledgments, completion records, and any complaint history.
Investigation Support When You Need It
If a complaint arrives, you are not researching how to run an investigation on the day it lands. Neutral third-party investigation matters more at this size than any other, because there is no one internally who can credibly investigate a colleague they work beside daily.
Training alone does not satisfy Labor Law 201-g.
The written policy must reach every employee at hire and again at each annual training, and it has its own list of required elements including a complaint form and an investigation procedure. It also has to be provided in an employee's primary language where the state publishes a template. We build the policy, the complaint form, and the delivery record together, because the training record on its own will not answer the question.
The obligation recurs, which is where small employers drift.
A company that trained everyone in year one and never repeated it is out of compliance by year two, and the gap is visible in exactly the records anyone would ask for. You pick the measuring date, calendar year or hire anniversary or anything else, and we run the cycle against it so the record does not depend on someone remembering.
Read what New York requires before you buy anything about it.
The New York compliance page covers the threshold, duration, cadence, content, recordkeeping, and penalties, with the statute cited so you can check it yourself.
Common questions
We have six employees in New York. Does this really apply to us?
How long does the training have to be?
Do we have to train our independent contractors?
When do we have to train someone we just hired?
What happens if we simply do not train?
Find out whether your program would survive the question.
In 30 minutes we review your policy, your training records, how a complaint would travel through your company, and whether the annual cycle and the policy delivery are actually documented. You receive a written gap report either way.