NYC sexual harassment training: the 15-employee rule explained

New York City employers with 15 or more employees must give annual interactive anti-sexual harassment training, covering eight content elements including bystander intervention and supervisors' responsibilities, keep records for at least three years, post a notice in English and Spanish and give new hires a fact sheet. Independent contractors count toward the 15, and anyone working more than 80 hours and at least 90 days in a calendar year must be trained¹².

These City rules sit on top of New York State's Labor Law § 201-g, which requires every employer in the state to train every employee annually. We cover the State rule in New York sexual harassment training requirements. This guide focuses on what the City adds.

Who counts toward 15 employees

According to the NYC Commission on Human Rights FAQ¹:

• the threshold is 15 or more employees at any point in the previous calendar year, or one or more domestic workers;
• employees are counted concurrently, not consecutively;
• employees outside the city count toward the 15;
• independent contractors count, whatever the hours or days they work.

Who must be trained

Employees, interns and part-time or short-term workers must be trained if they work more than 80 hours in a calendar year and for at least 90 days. Independent contractors follow the same test, and the 90 days need not be consecutive. Domestic workers must be trained regardless¹.

New staff should be trained as soon as possible after hire. The Commission notes that employers are liable for harassment by new employees from the first day.

Every calendar year

Employers must train every employee each calendar year. They may run the cycle on the calendar year, on each employee's start-date anniversary or on another date they choose¹.

The eight required content elements

Under Administrative Code § 8-107(30), the training must cover²¹:

1. that sexual harassment is a form of unlawful discrimination under local law;
2. that it is unlawful under state and federal law;
3. a description of sexual harassment, with examples;
4. any internal complaint process available to employees;
5. the external complaint processes: the NYC Commission on Human Rights, the NYS Division of Human Rights and the EEOC, with contact information;
6. the prohibition of retaliation, with examples;
7. information on bystander intervention;
8. the specific responsibilities of supervisors and managers, and the measures they may take.

The training must be interactive and accessible, including to staff with disabilities or limited English proficiency.

Records, poster and fact sheet

• Records: keep a record of every training for at least three years, such as a certificate or a signed acknowledgment, and make it available to the Commission on request.
• Poster: display the Commission's notice in English and Spanish in a conspicuous place at every worksite; remote workers can receive it electronically.
• Fact sheet: give the Commission's fact sheet to new employees at hire, no later than the end of their first week¹.

The free official training

The Commission offers a free online training in several languages, which it says meets both City and State requirements, provided the employer also shares its internal complaint process¹. It issues a certificate but keeps no records, so the employer must store them.

Supervisors' responsibilities in practice

Element 8 is where many trainings stay abstract. In practice, the supervisor's key moment is the conversation when someone reports. We cover it in receiving a sexual harassment complaint in New York.

Sexual harassment prevention in New York: receiving a report trains that conversation with an AI-simulated employee and a coach that flags each line. We do not claim it satisfies the City or State requirement on its own: it is unofficial awareness training, and your company must check it against the required content, add its own complaint process and keep its records.

See the course

FAQ

Do independent contractors count toward NYC's 15-employee threshold?

Yes. The Commission counts independent contractors toward the 15, whatever the hours or days they work.

Which NYC workers must be trained?

Anyone who works more than 80 hours in a calendar year and for at least 90 days, including interns, part-time workers and independent contractors.

How long must NYC employers keep training records?

At least three years.

Does NYC require bystander intervention training?

Yes. Bystander intervention is one of the required content elements.