One in four New York City AI and data science job posts still omits the salary range that Local Law 32 requires. ENTRA's Q2 2026 Job Signal Index puts the non-compliance rate for NYC AI and data science postings at 26%, placing the sector ahead of the broader New York tech-and-finance market, where Glassdoor's mid-2025 audit found fewer than 40% of all postings included any salary range at all, but well behind the 69% compliance rate logged by government and nonprofit employers in the same city. Four years into Local Law 32 of 2022, New York City's pay transparency mandate, the Commission on Human Rights has identified 288 salary transparency violation claims through active testing and filed 396 complaints, yet the law has never been tested in a single court proceeding. The compliance gap is widest exactly where the stakes are highest: senior AI roles carrying total compensation packages above $300,000.
What the Numbers Actually Show
ENTRA's Q2 2026 Job Signal Index puts non-compliance for NYC AI and data science postings specifically at 26%: one in four listings with no salary range. The Federal Reserve Bank of New York's broader analysis found roughly 24% of NYC-facing job advertisements failed to include the required range even in markets with multi-year enforcement histories, a corroborating order of magnitude. The AI sector outperforms the broader market: Glassdoor's mid-2025 audit of NYC postings across all tech and finance found compliance below 40%, meaning over 60% of that wider population was not disclosing. Government and nonprofit employers in the same city comply at 69%. The AI sector sits between those two benchmarks, and the gap between AI-specific compliance and government-sector compliance remains the enforcement story.
Local Law 32 is unambiguous. Any employer with four or more employees must include a minimum and maximum salary in every job advertisement for a position based in, or performable in, New York City. The NYC Commission on Human Rights can levy fines of up to $250,000 per violation. A company posting 200 non-compliant AI roles in a single quarter faces theoretical exposure of $50 million. The Commission has not issued a penalty anywhere near that ceiling. Its largest enforcement actions through H1 2026 remain in the five-figure range. As of February 2026, the law has not been tested in court, according to a Foley and Lardner analysis published that month.
The enforcement gap is where the behavior lives. The Commission's 2025 annual report flagged 21 Commission-initiated complaints, meaning they originated from internal testing rather than aggrieved applicants. Specific enforcement actions cited a $50,000-to-$180,000 posting range as failing the good faith standard (NYC Commission on Human Rights, 2025-2026 enforcement record, published NYCCHR complaints). A second action identified a $94,000 spread on a high-compensation role as too wide. Neither citation defined a numerical maximum spread percentage. As of August 2026, the Commission has not issued formal guidance setting a spread ceiling, which means the outer boundary of compliance remains a matter of legal judgment rather than published rule.
What NYC AI Employers Are Actually Posting
Posting behavior among the NYC employers tracked by the ENTRA Job Signal Index splits sharply between finance-adjacent firms and pure-play tech.
Palantir's New York office, which runs a significant share of the company's forward-deployed and commercial engineering roles, posts salary ranges in the $218,000-to-$380,000 band for senior machine learning and software engineering positions, per aggregated NYC posting data from ZipRecruiter and Glassdoor through Q2 2026. That $162,000 spread is tighter than the $180,000-to-$220,000 average band width logged at frontier AI labs in the same quarter (ENTRA Job Signal Index Q2 2026), and it sits within the range the Commission has not publicly challenged. For machine learning researchers specifically, Palantir's New York postings cluster between $211,000 and $354,000 in total compensation.
Goldman Sachs runs narrower. Levels.fyi data places Goldman's New York data scientist range at $151,000 to $227,000 for Analyst through Vice President, a $76,000 spread across two seniority levels. Individual Goldman postings on Glassdoor show ranges as tight as $125,000 to $155,000 per role, a $30,000 band that ranks among the narrowest in NYC financial AI hiring and one the Commission has no documented basis to challenge. JPMorgan posts wider. Aggregated job board data through Q2 2026 shows JPMorgan AI roles carrying ranges from $170,000 to $545,000 in total compensation across seniority levels (6figr, Glassdoor, Q2 2026). JPMorgan separates postings by grade, Associate through Executive Director, which narrows the within-posting spread to roughly $80,000 to $150,000 per band. That structure is legally defensible but uncommon in the market relative to Goldman's approach.
Two Sigma, with approximately 1,800 employees in New York, does not list salary ranges on the public-facing careers section of its website for senior quantitative research or machine learning roles, per ENTRA monitoring through July 2026. Citadel's New York office, which operates independently of the firm's Miami headquarters for research and technology hiring, similarly provides no public salary range data in its NYC-facing postings as of Q2 2026. Both firms run compensation structures where performance bonuses exceed base salary, and both appear to be testing whether bonus-dominated roles fall outside the "salary range" disclosure trigger in Local Law 32. The Commission has not published a ruling on that question.
Spotify, headquartered at 4 World Trade Center with recommendation-systems and AI engineering teams, was not confirmed to post salary ranges in its New York AI job listings through the ENTRA Q2 2026 monitoring window. Levels.fyi puts median total compensation for Spotify machine learning engineers in New York at approximately $247,000. No corresponding posting-level range was confirmed.
Three Things to Watch Before 2027
Local Law 144, the city's separate automated employment decision tools mandate, adds a second regulatory layer that Local Law 32 does not cover. Local Law 144 requires any employer using AI to screen, rank, or score candidates to conduct annual third-party bias audits, publish the results, and notify applicants before using any such tool. A December 2025 audit by the New York State Comptroller concluded that the Department of Consumer and Worker Protection's enforcement of Local Law 144 has been "ineffective," with no proactive identification of non-compliant employers (NYS Office of the State Comptroller, December 2, 2025). The Comptroller's report created political accountability for a tighter enforcement posture in 2026 and 2027. For AI companies in New York, the compliance surface is not Local Law 32 alone. It is Local Law 32 plus Local Law 144, and the second enforcement cycle is only beginning.
The Commission's band-width guidance is overdue. In April 2026, the Commission stated publicly that it intends to scrutinize ranges that "do not meaningfully constrain employer discretion." That language stops short of defining a maximum spread. If the Commission issues formal rulemaking setting a spread cap, employment counsel currently expect that cap to land somewhere in the 60%-to-100%-of-midpoint range. Every NYC AI employer currently posting a $162,000-to-$200,000 band would face immediate compliance work without changing a single offer letter.
The courthouse is the wildcard. Local Law 32 has survived four years without a judicial ruling. The first significant challenge, whether from an employer contesting a Commission fine or a plaintiff class alleging harm from non-disclosure, will set the precedent that has been missing since November 2022. That challenge is expected inside 2027. When it arrives, the firms with the cleanest posting records will have the clearest legal position, and Goldman's $30,000 bands will look like a different kind of strategy than they do today.
A Goldman Sachs data scientist posting at $125,000 to $155,000 is narrow enough to mean something. A JPMorgan AI band spanning $375,000 across grades technically complies. In Year Four of a law that has never been tested in court, the distance between those two postures is the practical definition of enforcement risk in New York City.
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