How Often Is Sexual Harassment Training Required in NY?

In New York, sexual harassment prevention training is required once a year for every employee, regardless of company size or whether the worker is full-time, part-time, seasonal, or temporary.¹ Employers in New York City with 15 or more employees carry the same annual obligation under the city’s Stop Sexual Harassment in NYC Act, plus a firm 90-day deadline for new hires.²

What “Once a Year” Actually Means

Labor Law 201-g says training must happen annually but does not define whether “annual” means the calendar year or a rolling 12-month period.¹ Both approaches are acceptable. Most employers pick one and stay with it: train everyone by a fixed date each year, or track each employee’s completion date individually and retrain within 12 months of the last session. What matters is that no employee ever goes more than a year without training.

Pick the method that fits how your workforce turns over. A fixed annual date is simpler to administer when your headcount is stable. Rolling 12-month tracking works better when you hire throughout the year and want new-hire training to reset each employee’s clock.

New Hires and the 90-Day NYC Deadline

State law requires employers to give new employees a written copy of the sexual harassment prevention policy at the time of hire, but it does not set a hard deadline for completing the training itself.¹ The safer practice is to train as soon as reasonably possible after the start date.

In New York City, the rule is more specific. Employers with 15 or more employees must complete training within 90 days of an employee’s initial hire date, and the requirement applies to any worker who puts in more than 80 hours in a calendar year.² After that first session, the employee then falls into the regular annual cycle.

Who Has to Be Trained

Every employee, full stop. There is no minimum headcount under state law: a one-person business has the same obligation as a large corporation.¹ Full-time, part-time, seasonal, and temporary employees all count.

Independent contractors are the common gray area. The state does not require employers to train independent contractors, vendors, or consultants. But under the state Human Rights Law, an employer can still be held liable for those workers’ conduct in the workplace, so the state encourages training anyone performing services on-site.³

What Each Annual Session Must Cover

You can use the state’s free model training or build your own, as long as any custom program meets or exceeds the state’s minimum standards.⁴ At a minimum, every annual session must include:

An explanation of what sexual harassment is, consistent with Department of Labor and Division of Human Rights guidance, with examples of unlawful conduct.
Information about federal and state laws prohibiting sexual harassment and the remedies available to victims.
All forums for filing a complaint, including internal processes, the Division of Human Rights, the EEOC, and the courts.
Specific content on supervisor responsibilities and their heightened obligations.

The training must also clearly state that retaliation against anyone who reports harassment or participates in an investigation is illegal.¹ NYC-covered employers must additionally cover bystander intervention and describe the complaint process available through the NYC Commission on Human Rights.²

Alongside the training, employees must receive a written copy of the company’s sexual harassment prevention policy at hiring and again at each annual session, in English and in the employee’s identified primary language.¹ If the state has not published a template in that primary language, the English version satisfies the requirement.

The Session Has to Be Interactive

Both state and city law require the annual training to be “interactive,” which does not mean it has to be in person. NYC’s definition includes any participatory format where trainees engage with the material: a live instructor, an audio-visual presentation, or an online program.²

What clearly does not count: pressing play on a training video and moving on. The state is explicit that a video alone does not meet the interactive standard. If you use the state’s model video, you must also do at least one of the following: ask employees questions during the program, allow employees to ask questions and receive timely answers, or collect feedback from employees about the training content.⁴ This is where a lot of small employers unknowingly fall short on their annual obligation.

New York offers a full set of free model materials, including a training script, slide deck, video, and an answer sheet employees can complete alongside the video to satisfy the interactive requirement.⁴ NYC provides its own free online interactive module through the Commission on Human Rights; employers using it still need to inform employees of any internal complaint process.²

Documenting Each Annual Session

State and city rules diverge sharply here.

State

New York State encourages employers to keep signed acknowledgments and training records, but the statute does not make signed acknowledgments mandatory. The state’s own FAQ describes these records as something employers “are encouraged to keep” because they “may be helpful in addressing any future complaints or lawsuits.”³ No specific retention period is set by state law. Skipping documentation is still risky. If a harassment claim reaches court, you will want proof that the employee was trained.

NYC

New York City is stricter. Employers covered by the city law must keep a record of every training, including a signed employee acknowledgment (electronic signatures are allowed). Those records must be retained for at least three years and made available for inspection by the NYC Commission on Human Rights upon request.² For NYC employers with 15 or more employees, treat the signed acknowledgment and three-year retention as hard requirements.

What Happens if You Miss the Annual Cycle

Under state law, violating any provision of the Labor Law, including the training requirement, is a misdemeanor. A first offense carries a fine of up to $100. A second offense brings a fine of $100 to $500, possible imprisonment for up to 30 days, or both. Subsequent offenses start at $300 in fines with up to 60 days of imprisonment.⁵ Officers and agents of a corporation who knowingly allow the violation can be held personally responsible.

The direct fines look modest. The real exposure shows up when an employee brings a sexual harassment claim and the employer never provided the required annual training. That gap becomes evidence, and it undermines the argument that the employer took reasonable care to prevent harassment.

In New York City, failure to provide annual training is a violation of the NYC Human Rights Law. Employees can file a complaint with the Commission on Human Rights, which can lead to civil penalties and damages beyond the state labor law fines.

1
New York State Senate. New York Labor Law 201-G – Prevention of Sexual Harassment
2
NYC Administrative Code Library. NYC Administrative Code 8-107 – Unlawful Discriminatory Practices
3
The State of New York. Combating Sexual Harassment in the Workplace – Employers
4
The State of New York. Sexual Harassment Prevention Model Policy and Training
5
New York State Senate. New York Labor Law 213 – Violations of Provisions of Labor Law