On December 19, 2025, New York Governor Kathy Hochul signed into law the “Trapped at Work Act” (the “Act”) (N.Y. Lab. Law §§ 1050–55) to prohibit certain types of so-called “stay-or-pay” agreements that require an employee to repay an employer for certain expenses or compensation if the employee terminates employment within a certain period of time after their start date.  These obligations often include repayment for expenses such as training, education, quit fees, damages clauses, sign-on-bonuses, and other types of cash payments tied to a mandatory stay period.  The Act, which took effect on December 19, 2025, is similar to a new California law that took effect on January 1, 2026.

The New York Act and the new California statute follow on the heels of the National Labor Relations Board’s (“NLRB”) February 2025 recission of a 2024 NLRB General Counsel memorandum, which proposed that the NLRB adopt a framework to presume that any stay-or-pay provision is unlawful even if entered into voluntarily.  The NLRB’s recission of this memo paved the way for New York and California (and potentially other states) to regulate stay-or-pay agreements at the state level.

“Employment Promissory Notes” Prohibited

The New York Act prohibits employers from requiring that any “worker” enter into an “employment promissory note” as a condition of employment.  An “employment promissory note” is “any instrument, agreement, or contract provision that requires a worker to pay the employer, or the employer’s agent or assignee, a sum of money if the worker leaves such employment before the passage of a stated period of time.”  Employment promissory notes also include any “instrument, agreement, or contract provision which states such payment of moneys constitutes reimbursement for training provided to the worker by the employer or by a third party.”  Notably, the Act defines “worker” expansively to include employees, independent contractors, externs, interns, volunteers, apprentices, sole proprietors, and individuals who provide services through a business or nonprofit entity or association.

Any such contracts are unconscionable and against public policy, and are null and void, although impermissible employment promissory note terms included within a larger agreement would not invalidate other provisions of the agreement.  An employer that enters into or tries to enter into an employment promissory note may be fined up to $5,000 per violation.  And, if an employer sues an “employee” (as opposed to a “worker”) to enforce a null and void employment promissory note, the employee can recover attorneys’ fees if the employee prevails.  The Act only prohibits the execution of employment promissory notes after the effective date of December 19, 2025, but it is not clear whether the potential penalties and awards of attorneys’ fees would apply to disputes involving agreements entered prior.  We expect that any attempt to apply the Act retroactively would be challenged in court.

Certain Stay-or-Pay Terms Still Permitted

The Act carves out certain types of provisions from its prohibition on stay-or-pay terms.  These carveouts include provisions that:

  • require workers to repay to an employer any sums advanced to such worker by the employer, unless the sums were used to pay for training related to the worker’s employment with the employer;
  • require workers to pay an employer for any property it has sold or leased to the worker;
  • require educational personnel to comply with terms or conditions of sabbatical leaves granted by their employers; or
  • are part of a program agreed to by the employer and its workers’ collective bargaining representative.

Note that while the statute is not entirely clear, it is likely that certain common reimbursement arrangements, such as for sign-on bonuses or relocation expense advances, would be covered by the first carveout above so long as the funds are not related to training.

Proposed Amendments

On January 6, 2026, New York Assemblymember Phil Steck introduced Bill A09452, which proposes several amendments to the Act.  The amendment, if passed, would delay the effective date of the law until December 19, 2026, and restrict application of the Act to employees.  The amendment would also clarify certain carveouts, including:

  • Agreements/terms for reimbursement of tuition, fees, and required educational materials for a “transferable credential” would have to (i) be in writing and separate from any contract of employment, (ii) not require the employee to obtain the credential, (iii) specify the repayment amount, which does not exceed the cost to the employer, (iv) provide for prorated repayment proportional to the length of required employment and does not accelerate repayment on separation, and (v) not require repayment on a termination of employment by the employer, unless the termination is for misconduct.
  • For provisions requiring repayment for property sold or leased to an employee, the sale or lease must have been voluntary.

The amendment also adds a carveout for agreements that require the employee to repay a financial bonus, relocation assistance, or other non-educational incentive or other payment or benefit that is not tied to specific job performance, unless the employee was terminated for any reason other than misconduct or the duties or requirements of the job were misrepresented to the employee.  Finally, the amendment would give the New York State Commissioner of Labor discretion in awarding penalties for violations to consider the size of the employer’s business, the good faith basis for why the business thought it was in compliance with the Act, the gravity of the violation, and history of violations.

Looking Ahead in New York and California

New York employers should keep an eye on the proposed amendment.  But in the meantime, because the Act is currently in effect, New York employers should take stock of their template offer letters and employment agreements and consult with counsel on how to revise these agreements to comply with these new updates. 

Also, as further detailed in our California Update: New Employment Laws and Compliance Obligations for 2026, beginning January 1, 2026, employers in California are prohibited from either including in an employment contract or requiring a worker to execute as a condition of employment or work relationship, the following types of contract terms that: (1) require a worker to pay an employer, training provider, or debt collector for a debt if the employment or other work relationship terminates; (2) authorize the employer, training provider, or debt collector to resume or initiate collection or end forbearance on a debt if the relationship terminates; or (3) impose any penalty, fee, or cost on a worker if the relationship terminates. 

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Photo of Evan Parness Evan Parness

Evan Parness, vice chair of the firm’s Employment Practice Group, has a full-service labor and employment practice that includes litigating cutting-edge issues at the trial and appellate levels, negotiating employment aspects of complex M&A deals and other business transactions, and counseling global employers…

Evan Parness, vice chair of the firm’s Employment Practice Group, has a full-service labor and employment practice that includes litigating cutting-edge issues at the trial and appellate levels, negotiating employment aspects of complex M&A deals and other business transactions, and counseling global employers on compliance with national, state, and local employment laws and regulations.

Evan represents employers and senior executives in non-compete, harassment, discrimination, retaliation, ERISA, and business tort litigation in state and federal courts, administrative agencies, and alternative dispute resolution bodies. He has secured significant trial and appellate victories for clients, including complete dismissals of discrimination and retaliation lawsuits, successful verdicts following trial, and injunctive relief on behalf of clients enforcing restrictive covenants.

Evan also counsels established and emerging companies on compliance with federal, state, and local employment laws and regulations, and litigation avoidance measures in connection with all aspects of workplace employment issues. He conducts sensitive internal investigations of alleged discrimination and harassment, and assists employers in shaping workplace policies to comply with law and promote a productive working environment.

Evan advises leading companies on the labor and employment aspects of significant business transactions and acquisitions. He negotiates employment-related provisions in business transaction documents and oversees due diligence of a potential target’s employment practices. He also counsels clients on executive employment and restrictive covenants agreements.

Chambers USA notes “Evan is an exceptional and talented lawyer. He possesses a deep understanding of the law and an unwavering commitment to his clients. He has a keen eye for detail and can dissect complex legal issues with remarkable efficiency. His thorough and methodical approach to each case ensures that no stone is left unturned, providing his clients with the best possible legal representation.”

The Legal 500 US notes that clients have commented that “Evan Parness is an amazing attorney. Always attentive and will take instructions outside of business hours, he is always there when we need him and looks for the best outcome for clients.”

Photo of Carolyn Rashby Carolyn Rashby

Carolyn Rashby provides business-focused advice and counsel to companies navigating the constantly evolving and overlapping maze of federal, state, and local employment requirements. Carolyn’s approach is preventive, while recognizing the need to set clients up for the best possible defense should disputes arise.…

Carolyn Rashby provides business-focused advice and counsel to companies navigating the constantly evolving and overlapping maze of federal, state, and local employment requirements. Carolyn’s approach is preventive, while recognizing the need to set clients up for the best possible defense should disputes arise.

As a senior member of Covington’s Institutional Culture and Social Responsibility Practice Group, Carolyn has co-led significant investigations into workplace culture, DEI issues, and reports of sexual misconduct and workplace harassment.

As an employment lawyer with over two decades of experience, Carolyn focuses on a wide range of compliance and regulatory matters for employers, including:

Conducting audits regarding employee classification and pay equity
Advising on employment issues arising in corporate transactions
Strategic counseling on a wide range of issues including discrimination and harassment, wages and hours, worker classification, workplace accommodations and leave management, performance management and termination decisions, workplace violence, employment agreements, trade secrets, restrictive covenants, employee handbooks, and personnel policies
Drafting employment contracts and offer letters, separation agreements, NDAs, and other employment agreements
Advising on employee privacy matters, including under the California Consumer Privacy Act
Providing guidance on use of AI in the workplace and development of related policies
Leading anti-harassment and other workplace-related trainings, for employees, executives, and boards

Carolyn also works frequently with the firm’s white collar, privacy, employee benefits and executive compensation, corporate, government contracts, and cybersecurity practice groups to ensure that all potential employment issues are addressed in matters handled by these groups.

Photo of Zachary Agudelo Zachary Agudelo

Zach Agudelo is an associate in the firm’s Washington, DC office and is a member of the firm’s Employment, Employee Benefits and Executive Compensation, and Institutional Culture and Social Responsibility Practice Groups. He routinely advises clients on a range of labor, employment, and…

Zach Agudelo is an associate in the firm’s Washington, DC office and is a member of the firm’s Employment, Employee Benefits and Executive Compensation, and Institutional Culture and Social Responsibility Practice Groups. He routinely advises clients on a range of labor, employment, and employee benefits related issues, including wage and hour compliance, job classifications, restrictive covenants, workplace policies, incentive plans, and executive compensation. His practice also includes employment- and employee benefits-related diligence and advise in corporate transactions.

In addition, Zach assists both private and non-profit clients with matters involving harassment, discrimination, retaliation, and other issues arising under state and federal employment laws, including Title VII of the Civil Rights Act of 1964, the Equal Pay Act, and the Fair Labor Standards Act. He also has extensive experience conducting civil rights and racial equity assessments for corporations and advises clients on the lawful design of diversity, equity, and inclusion practices.