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The New York State Human Rights Law (N.Y. Exec. Law § 296) applies to employers of all sizes. Amendments phased in from 2019 removed the former four-employee floor, so every New York employer now carries a state-law duty regardless of headcount.
“Disability” is defined more broadly than under the ADA, covering any physical, mental or medical impairment that is demonstrable by medically accepted techniques, or a record or perception of one, with no requirement that it limit a major life activity. Pregnancy-related conditions are separately protected under §§ 292 and 296, and since January 1, 2025 New York has been the first state to guarantee paid prenatal leave: 20 hours per year for prenatal care, at any employer size.
Employers must provide reasonable accommodations to qualified individuals with disabilities so they can perform the essential functions of the job, unless doing so would impose an undue hardship. Examples include modified schedules, accessible worksites, assistive technology, job restructuring, leave, and modified policies. The law also requires reasonable accommodation for pregnancy-related conditions, religious observance, and victims of domestic violence.
For pregnancy, a condition need not rise to the level of a disability; the statute covers any medical condition related to pregnancy or childbirth that inhibits the exercise of a normal bodily function or is demonstrable by medically accepted techniques, including lactation. Listed accommodations include more frequent breaks, seating, light duty, modified schedules, and time off for prenatal care and recovery.
Employers may request documentation to verify a disability or pregnancy-related condition where it is not obvious, limited to confirming the condition and the need, and must keep it confidential. Section 296(3) requires a good-faith interactive process, and the Division of Human Rights treats unexplained delay or refusal to engage as evidence of a violation. There is no fixed statutory deadline.
New York City. Employers with four or more employees in the city face additional obligations under the NYC Human Rights Law.
They must provide written notice of pregnancy-accommodation rights to new employees at hire and to any employee who notifies the employer of a pregnancy, and must engage in a cooperative dialogue on any accommodation request for disability, pregnancy, religion or domestic violence, concluding with a written final determination to the employee stating whether the accommodation is granted or denied. Failing to conduct the dialogue is an independent violation.
Since July 5, 2023, Local Law 144 has also required a bias audit and notice before any automated employment decision tool is used in hiring or promotion within the city.
New York’s Paid Family Leave and Paid Sick Leave run alongside accommodation duties. Statewide, since 2025 the Human Rights Law also codifies a disparate-impact standard for employment claims (S4067A).
Complaints are filed with the New York State Division of Human Rights within three years of the alleged act (for claims arising on or after February 15, 2024; one year for earlier claims), or directly in court within three years. Damages are not capped and include emotional distress; punitive damages and attorney fees are available in employment cases.
New York City claims go to the NYC Commission on Human Rights within one year, or to court within three.
Managing accommodation requests under the New York State Human Rights Law can be tedious—multiple forms, interactive‑process deadlines, and cross‑department coordination all add complexity.
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This guide is provided for general informational purposes only and does not constitute legal advice. Employment laws change frequently and vary by jurisdiction. Consult qualified employment counsel before acting on any information here. Last reviewed: September 2026.
