New York DOL Clarifies “Trapped at Work Act” Ahead of December Effective Date
Seyfarth Synopsis: The New York State Department of Labor (“DOL”) has issued guidance addressing several open questions under New York’s Trapped at Work Act (“Act”), which takes effect December 19, 2026. Among other clarifications, the DOL confirms that the Act applies only to new agreements or new or amended terms in existing agreements entered into on or after the effective date, and that genuinely voluntary repayment arrangements may fall outside the Act…

