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Background

Employers have long had the upper hand in negotiating salary with job seekers. While an employer’s power shifts based on the tightness of the labor market, one advantage is a constant: only the employer has full information about what it is truly willing to pay. In recent years, various state and local legislatures across the United States have begun to take aim at this imbalance. The New York City Council has been at the forefront of this movement, first introducing a salary transparency bill in October 2018. Former Councilmember Helen Rosenthal, the bill’s original sponsor, called salary transparency “an actionable way to create a more equitable workplace, both leveling the playing field for job applicants and helping to identify and address systemic pay inequities.” The law requires employers and their agents to state the minimum and maximum salary “in good faith” for all positions in job listings. The law applies to “employment agencies,” to employers with four or more employees or one or more domestic workers, and to any agent thereof. It exempts temporary staffing agencies and any “position that cannot, or will not be performed at least in part, in the City of New York.”

Salary Transparency Rose by 138% in the NY-NJ-PA Metro Area within a Year of Local Law 32’s Implementation.

Feb 2022 vs Feb 2023
Indeed Hiring Lab

Since November 2022, with the passage of Local Laws 32 and 59 (“the Salary Transparency Law”), jobs posted in New York City must include salary information, putting an essential tool in the hands of job applicants as they seek a fair and equitable wage. Now that the Salary Transparency Law has been in effect for two years, the Council’s Oversight and Investigations Division (OID) and Legislative Division’s Data Team (“Data Team”), have conducted an assessment of the effectiveness of the law to date. OID investigated and analyzed enforcement efforts at the New York City Commission on Human Rights (CCHR), the agency responsible for enforcing the Salary Transparency Law. OID also met with senior staff at CCHR, submitted written questions to the agency, and reviewed publicly available information about the agency’s enforcement of the law. In addition, to evaluate compliance with the law in the universe of job postings in New York City, the Data Team analyzed more than 60,000 unique job postings from Indeed and Google for Jobs over a period of approximately two months in late 2023.

The Council’s investigation found that while most job postings in New York City are compliant with the Salary Transparency Law, and CCHR has made a substantial effort to enforce the law, additional steps may be taken to improve salary transparency in the city. This report includes several recommendations related both to the law itself and to CCHR’s enforcement efforts.

This is an abridged version of the Salary Transparency Law Report. You can click below for the full report.

Access the full OID-Data Team salary transparency report

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Executive Summary

Findings

Job Search Platforms

Jump to the Job Search Platforms section

Job search platforms may lose salaries when “scraping” postings from other sites. The Council’s analysis found that 11% of New York City job listings posted on Indeed and 44% of those posted on Google for Jobs during the collection period lacked the required salary range. This issue is likely tied to the methods both platforms use to “scrape” and aggregate job postings from other sources.

Wide Salary Ranges

Jump to the Wide Salary Ranges section

Wide salary ranges in New York City job postings are rare. Among job postings that included a salary range as required, more than 80% had a maximum salary that was no greater than 1.5 times the minimum salary (e.g., “$50,000 to $75,000,”). Furthermore, in all but 3% of stated salary ranges, the maximum salary listed was less than double the minimum salary listed.

CCHR Enforcement Actions

Jump to the CCHR Enforcement Actions section

For years, CCHR has struggled to maintain full staffing, especially for attorney positions. The number of employees at CCHR fell from 134 in 2019 to 103 in 2023, and the number of legal staff fell from 29 to just 13 over the same period. According to CCHR, the agency currently has 112 active employees, despite an approved headcount of 136. This staffing shortage is directly reflected in a reduction in CCHR’s filed complaints, which decreased by 42% from FY18 to FY23. At the same time, the agency’s mandate has only grown. According to The Legal Aid Society, the NYCHRL has been amended 40 times since 2013.

CCHR brought complaints against a broad range of entities.
Of the 32 publicly available CCHR-initiated cases, 28 were against employers and four were against companies maintaining widely known job search platforms. The employers spanned a wide range of industries, including finance, automobiles, and media.

CCHR does not sufficiently report its salary transparency enforcement results or seek to publicize them.In its publicly available information regarding salary transparency cases, CCHR reveals very little about the outcomes of closed cases. This leaves the public uninformed as to what CCHR has achieved from its enforcement of the law. In the past, the agency has posted “Settlement Highlights” for certain cases, noting whether the agency imposed a monetary penalty or required specific actions from a respondent. However, for Salary Transparency Law cases, CCHR has not made a single public announcement, even as it closed 27 agency-initiated cases.

Recommendations

The Administration should fully fund and staff CCHR to adequately enforce legal protections of New Yorkers.

Despite the Council’s call for the Administration to restore funding for CCHR to pre-pandemic levels, it has not yet done so. Furthermore, OMB and CCHR must prioritize filling vacancies within the Commission’s Law Enforcement Bureau and implement measures to retain staff.

CCHR Should Publicize the Outcomes of Closed Salary Transparency Cases

Failing to share this information represents a missed opportunity to promote compliance with the law and to deter those who might violate it in the future. As it has for other antidiscrimination cases, the Commission should issue press releases describing the outcomes of its closed salary transparency cases. Additionally, the Commission should promptly publish as much case documentation of closed cases as is feasible, enabling the public to understand whether companies admitted liability, paid a penalty, or committed to taking steps to avoid future violations.

Mayoral offices, City agencies, and the New York State Department of Labor (NYSDOL) should collaborate with CCHR to promote and ensure widespread compliance with the law.

Administration officials should support CCHR in advancing compliance efforts, leveraging the reach of City agencies that engage with employers and job seekers to publicize CCHR’s cases and emphasize the importance of complying with the law. Additionally, CCHR should strengthen its coordination with NYSDOL, which oversees enforcement of the state’s salary transparency law, to align efforts and maximize impact.

CCHR should consider strategies to discourage the use of wide salary ranges.

The agency could take several actions, including publishing legal enforcement guidance indicating that ranges exceeding a certain size will be prioritized for investigation. Additionally, CCHR could issue a rule requiring employers or employment agencies to provide justification for posting wide ranges.

CCHR Should Consider How to Address Missing Salaries in “Scraped” Job Postings

CCHR should consider how it can best ensure that job seekers consistently see the required salary ranges on job postings, even when postings are “scraped” from other sites and reposted on job search platforms. To achieve this, CCHR could engage directly with job search platforms to identify effective solutions, and could publish recommendations that “scraped” postings include links to original postings or disclaimers explaining the law’s requirements.


Enforcement of the Salary Transparency Law

Today, CCHR protects New Yorkers from being discriminated against on the basis of race, religion, gender, sexual orientation, source of income, veteran status, caregiver status, disability, and many more protected categories, in employment, housing, and public accommodations. CCHR has the authority to bring complaints against any individual or business that violates New York City Human Rights Law (NYCHRL).

Historically, while CCHR may bring antidiscrimination cases on its own initiative, it brings far more on behalf of complainants. Last year, for example, across all types of cases, CCHR filed 332 complaints, but only 46 were agency-initiated. For Salary Transparency Law cases, however, CCHR filed far more agency-initiated cases. CCHR told OID that “[a] key takeaway is that the individuals most interested in filing complaints at the Commission are individuals who believe that a post has not been posted in good faith. Those who call to report a missing range are less interested in filing a complaint and content leaving tips for the Commission to follow up on.” CCHR has also begun proactive testing for salary transparency violations, conducting 190 tests in FY23 and 295 in FY24 (15% and 23%, respectively, of the agency’s total tests).

Report discrimination
on CCHR’s online form
or by calling
(212) 416-0197.

The Commission on Human Rights accepts and investigates complaints of discrimination filed by members of the public, including complaints alleging violations of the new salary transparency protection.

For more on OID’s review of CCHR, click here to the full report.


Analysis on New York City Job Listings and Salary Ranges


89% of job postings on Indeed included salary information compared to 56% on Google for Jobs.

November 2023

To better understand the state of salary transparency in New York City, the Data Team analyzed job listings from Indeed and Google for Jobs. To examine and compare the salary ranges across job postings, a salary ratio was calculated by dividing the maximum salary by the minimum for a given salary range. For example, if the maximum salary was $100,000 and the minimum was $50,000, the ratio would be $100,000/$50,000 = 2 (in cases where only a single number, such as $20 per hour or $70,000 annually, was given, the ratio is 1). Additionally, company information was “scraped” from Indeed to facilitate further analysis of job industries. From our analysis, 89% and 56% of listings, respectively, included the required salary information.

Methodology

Methods

Data Collection & Metrics

Background on Data Sources

To identify eligible jobs postings for this analysis, location filters were applied on each platform’s search results. The team set the location as “New York, New York” and filtered to “Exact location only” on Indeed. On Google for Jobs, filters were set to “New York, New York” and “within 15 miles.” The phrase “New York City jobs” was also entered into the Google for Jobs search bar, utilizing the precision of Google’s algorithm to avoid including jobs beyond city borders. This resulted in the collection of approximately 49,000 unique job postings from Indeed and 16,500 from Google for Jobs over an approximately two-month period in October and November 2023. This represents a majority of job postings during this time period (according to the New York City Economic Development Corporation, there were approximately 100,600 New York City job postings during this period). To maximize data collection, four daily scrapes were conducted on each site, which captured and collected posts made within the previous 24 hours. Salary details were collected using designated salary containers for Indeed and both containers and text-based job descriptions for Google for Jobs.

Founded in 2004, Indeed is one of the most visited online job search engine websites in the US. The site aggregates job listings from websites—including job boards, staffing firms, associations, and company career pages—in addition to allowing employers to post directly to its job board. Starting in July 2022, Indeed publicly committed to “clearly list salary information on every job listing whenever an employer provides it.” In cases where employers fail to provide this information, Indeed shows an estimated salary range when it has “enough confidence” in its data. They do not provide estimates for commission-only based jobs. Indeed was selected for this analysis because of its popularity, as well as for the company’s purported support and study of salary transparency. Launched in 2017, Google for Jobs aggregates listings from job boards and career sites and features them prominently in Google Search. Google for Jobs is not a job board itself, but rather an “enhanced search tool.” It “scrapes” postings published on hundreds of third-party job sites but does not allow employers to post jobs directly on the site. Google for Jobs was selected for this analysis to provide a broader picture of salary transparency across the internet.

Example Salary Ratio Calculations:

Example Google for Jobs Listing:

Salary container shown in red and job description shown in blue

Example Google for Jobs listing

For more on the Data team’s methodology, findings, and analysis, click here to the NYC Council’s GitHub repository (link).


Job Search Platforms

Investigating Missing Salaries

Some portion of the missing salary ranges on both platforms are likely due to the way each of these large job platforms “scrapes” for job listings from other sites; in other words, the way Google for Jobs and Indeed pull job postings from other websites to post them on their sites. In some cases, it appears that salary ranges posted on the original website were lost during that process. For instance, job postings from NYC Health and Hospitals Corporation (H+H) on Indeed rarely included salary information—300 out of 374 postings (more than 80%) lacked this detail. However, the Data Team found that the original listings on H+H’s website did include salaries, suggesting that the “scraping” process failed to transfer this information.

The issue of missing salary information is even more pronounced on Google for Jobs than on Indeed. Of the Google for Jobs postings analyzed by the Data Team, 44% were missing a salary.

Analyzing Google for Jobs’ top sources shows the pitfalls of one job board platform “scraping” job postings from another such platform. Of the Google for Jobs postings sourced from LinkedIn, a large source of postings, 49% lacked a salary range. Similarly, a majority of Google for Jobs’ posts sourced from Trabajo.org, GrabJobs, and BeBee were missing salary information: 77%, 73%, and 64%, respectively.

Example of Salary being lost through repostings from the original

Sources With Job Postings That Most Frequently Have
Empty Salary Containers On Google For Jobs


Sources where 85% or more of postings had an empty salary container on Google for Jobs, sorted by number of total postings (only includes sources with 100 or more postings)

Wide Salary Ranges

Determining the Width of Salary Ranges

The Data Team analyzed the listed salary ranges for job postings that included salary ranges. To calculate the ratio for a given job posting’s salary range, the Data Team divided the maximum salary by the minimum. As shown in the below chart, of the job postings the Data Team collected from Indeed, 85% had a salary ratio below 1.5, and 97% had a salary ratio below 2. Similarly, of job postings collected from Google for Jobs, 80% had a salary ratio below 1.5 and 97% had a salary ratio below 2. In other words, in all but 3% of job postings, the maximum salary listed was less than double the minimum salary listed.


In only 3% of job postings, the maximum salary listed was less than double the minimum salary listed.

Collected from Indeed & Google for Jobs
November 2023

The Distribution of Salary Ratios

Buckets chosen for simplification.

Industries with the Widest Salary Ratios

Of the job titles with the widest salary ratios on Indeed, a large majority appear to be performance or commission-based roles, with titles including “Agent,” “Representative,” “Manager,” and “Sales.” A theory for this observed pattern could be that many such workers in these titles rely on commissions or bonuses atop a fixed salary, so some employers may include estimated totals in the listed “salary” to draw talent.

In addition, certain industries in the Indeed dataset have median salary ratios that are particularly high. Some examples of industries with the widest median salary ratios include stock exchanges (1.86), insurance carriers (1.65), financial transaction processing (1.59),  internet and web services (1.28), and real estate agencies (1.23).

Examples of Industries
with Salary Ratios
Higher than Average

The upper salary range exceeds the lower by more than 17%.

Financial Transaction Processing (1.67x)

  • Amex (1.87x)
  • Western Union (1.67x)

Insurance Carriers (1.65x)

  • EmblemHealth (1.76x)
  • Global Atlantic Financial Group Opportunities (1.90x)

Investment & Asset Management (1.50x)

  • BNY Mellon (1.86x)
  • Citi (1.50x)

Pharmaceutical & Biotechnology (1.44x)

  • Pfizer (1.67x)

Telecommunications (1.42x)

  • Verizon (1.86x)
  • Comcast (1.50x)

Acknowledgements
NYC Council Speaker Adrienne Adams thanks the Oversight and Investigations Division, specifically, Amisa Ratliff, Policy Analyst; Katie Sinise, Investigator; Uzair Qadir, Data Scientist; and Brian Parcon, Legislative Counsel, under the supervision of Assistant Deputy Directors Kevin Frick and Zachary Meher-Casallas, and Acting Director Meagan Powers; and the NYC Council’s Data Team, specifically, Data Scientists Rachel Avram and James Wu, under the supervision of Assistant Deputy Director Rose Martinez, for their efforts in producing this report.

She also thanks the Council’s Community Engagement Division, specifically, Production Assistant Brittany Ng and Senior Designer Antonio Rodriguez, under the supervision of Director of Event and Production Services Cassandra Tennyson. Appreciation is extended to the NYC Commission on Human Rights for its assistance and cooperation.


 For feedback, comments, and questions please email DataInfo@council.nyc.gov.

Created by the NYC Council Data Team