New York Requires Companies to Disclose AI Role in Mass Layoffs

New York State introduced a requirement in March 2025 for employers to indicate if artificial intelligence or automation contributed to mass layoffs. This policy aims to increase transparency about the impact of technology on workforce reductions.

The amendment to the state’s WARN Act applies to businesses with at least 50 employees. Employers filing notices for mass layoffs must specify whether technological innovation, including AI, played a role in job losses. The reporting requirement was initiated by Governor Kathy Hochul, who directed the Department of Labor to update the filing process.

New York is the first state in the United States to mandate this type of disclosure. The option to cite “technological innovation or automation” was added to the WARN filing form around eleven months before February 2026. If employers select this option, they are prompted to identify the specific technology, such as AI, robotics, or software modernization.

Governor Hochul proposed the inclusion of AI-related questions in WARN filings during her State of the State address in January 2025. State lawmakers have since introduced additional proposals to expand workforce reporting requirements related to AI, which include annual estimates of unfilled positions due to automation and linking compliance to eligibility for state grants and tax benefits.

What the numbers show

• More than 160 companies filed WARN notices in New York by early 2026
• Nearly 28,300 workers were affected by these filings
• No WARN filings during this period cited AI or automation as the cause

Companies such as Amazon, Goldman Sachs, and Morgan Stanley were among those submitting WARN notices since the new reporting rule took effect. Despite the new requirement, none of the filings indicated that AI or automation contributed to the workforce reductions.

The state’s updated WARN form asks employers to specify the type of technology involved if they report automation as a factor. This includes options for AI, robotics, and other forms of technological modernization. The process is designed to collect more detailed information about the reasons behind mass layoffs.

Legislative proposals currently under consideration would further expand the reporting framework. These measures would require companies to estimate the number of jobs left unfilled due to AI and tie compliance with reporting rules to access to certain state incentives.

New York’s approach to AI-related layoff disclosure represents a procedural change in workforce reporting. Other states have not yet implemented similar requirements for employers regarding the role of automation in job losses.

* This article is based on publicly available information at the time of writing.