***UPDATE: New York City has issued further guidance regarding implementation of the private employer vaccine mandate.  Read more here.***

Mayor Bill de Blasio has announced that New York City will become the first major city in the United States to mandate COVID-19 vaccinations for private sector workers across industries. The mandate will take effect on December 27, 2021 and will apply to approximately 184,000 businesses.

According to the NYC Health website, starting December 27, all employees at private sector businesses must have received at least one dose of a COVID-19 vaccine.  This requirement will not be limited to businesses in certain industries or based on company size.  While further details are presently limited, the City is expected to issue additional enforcement and reasonable accommodation guidance by December 15, 2021, as well as provide additional resources to help small businesses with implementation.

In addition to the private sector vaccine mandate, the Mayor further announced expansions to the “Key to NYC Pass” program first implemented on August 17, 2021, which currently mandates workers and patrons ages 12 and over to show proof of having received at least one dose of a COVID-19 vaccine in order to have access to, or provide services within, indoor dining, indoor fitness, and indoor entertainment venues and performances.  Starting December 14, 2021, the program will require children ages 5-11 to show proof of at least one vaccination dose for access to such venues.  Further, starting December 27, 2021, children and adults ages 12 and older will be required to show proof of two vaccine doses, instead of one, except for those who have received the Johnson & Johnson one-dose vaccine.

We will continue to monitor and report on further developments with regard to these new requirements as they arise.