Local Law 61 of 2026 took effect July 28, 2026. It sets no dollar figure of its own: it pegs guard pay to the City Comptroller's prevailing wage schedule, which currently runs $18.87 to $33.70 an hour depending on classification, plus $8.47 an hour in supplemental benefits. The wage obligation starts January 1, 2027, and DCWP posts the schedule that governs it on September 1, 2026. Records stay live for six years, and an underpayment carries double liquidated damages on top of the shortfall.
This article is for general information and is not legal advice. Confirm obligations with qualified counsel.
The Aland Etienne Safety and Security Act, enacted as Local Law 61 of 2026 and codified at Administrative Code Title 20, Chapter 16, took effect on July 28, 2026[1]. It requires any employer of registered security guards in New York City to provide wages, paid time off and supplemental benefits at least equal to those required for private sector security guards engaged on New York City public building service contracts in excess of $1,500[1]. Those rates are set in the City Comptroller's prevailing wage schedule for building service employees[2], and the obligations phase in over three years starting January 1, 2027[1][3]. The Council passed the law over a mayoral veto on January 29, 2026[4]. 32BJ SEIU, the union that campaigned for it, puts the affected workforce at roughly 60,000 guards[5][6].
What does NYC's Security Guard Wage Law require?
The law establishes minimum wage, paid time off, and supplemental benefit standards for registered security guards in New York City, phased in over three years[1]. The Council named it for Aland Etienne[7], a 46-year-old security officer and 32BJ SEIU member killed while protecting others during the July 2025 mass shooting at 345 Park Avenue[5].
Here's the compliance timeline every security employer needs to track:
| Date | What takes effect |
|---|---|
| July 28, 2026 | Law effective. Guards already employed must receive the DCWP Notice of Employee Rights within 30 days, in English and in the guard's primary language where DCWP has published a version in that language |
| September 1, 2026 | DCWP must post the minimum wage, paid time off and supplemental benefit levels the chapter requires, and annually after that |
| January 1, 2027 | Wage floor begins |
| January 1, 2028 | Paid time off begins, covering holidays, vacation and sick leave |
| January 1, 2029 | Supplemental benefits begin, a defined list that runs from medical and pension through life, disability and accident insurance |
| On expiry of a qualifying agreement | Guards under a collective bargaining agreement that expressly waives these provisions and delivers an equal or better package, or under a pre-October 30, 2025 designated agreement, come into scope when that agreement terminates |
One point of order on those dates, because it is easy to read the wage requirement as settled. The statute names no dollar figure. It points to the wage required for private sector security guards on New York City public building service contracts over $1,500[1], which is the Comptroller's building service employee schedule under Labor Law Article 9[2]. DCWP posts its own schedule on September 1, 2026, and that is the one that will govern the January 1, 2027 obligation[1][3]. As of August 6, 2026, DCWP had not posted it, and had not published the Notice of Employee Rights that employers were required to distribute within 30 days of July 28[3]. If you need to know what to hand a guard in the meantime, DCWP is the authority to ask.
Here is what the Comptroller's schedule currently requires. These figures hold for July 1 through December 31, 2026, and the supplemental rate steps up on January 1, 2027, the same day the wage obligation begins[2]:
| Guard classification | Hourly wage | Supplemental benefits |
|---|---|---|
| Security Guard (Unarmed), 0 to 36 months | $18.87, rising to $19.68 on May 1, 2027 | $8.47, rising to $8.77 on Jan 1, 2027 |
| Security Guard (Unarmed), certified | $22.20, rising to $23.15 on May 1, 2027 | $8.47, rising to $8.77 on Jan 1, 2027 |
| Security Guard (Armed) | $33.70, rising to $34.65 on May 1, 2027 | $8.47, rising to $8.77 on Jan 1, 2027 |
The second row is where payroll teams go wrong, because it is not a seniority tier. To reach $22.20 an unarmed guard must have twelve months of employment and FDNY F-01, F-03 and F-04 certifications, and FDNY Building Evacuation Supervisor training, and two hours of customer service and professionalism training[2]. A guard who simply stays two years does not move up. The entry classification runs to 36 months, so an uncertified guard sits at $18.87 for three years while a certified colleague thirteen months in earns $22.20.
Two more mechanics in the same schedule are worth reading before you configure anything. The supplemental rate is payable for each hour paid, capped at 40 paid hours per week. And months of employment count an employee's service with the employer or at the facility, whichever is greater[2], so a contractor that wins a building inherits the tenure the incumbent guards built there.
Coverage is broader than the $1,500 figure suggests, and this is the most common misreading of the law. The $1,500 threshold describes the city contracts that set the benchmark, not the employer's own book of business. A covered employer is any person who employs one or more covered security guards in New York City, with no contract-value test at all[1]. What narrows it is the guard: someone employed to principally perform the functions listed in General Business Law section 89-f(6) who is required to hold a current, valid registration card under Article 7-A of that law[1]. Registration status, not building type, is the test.
The exclusions are also wider than "government is exempt." The federal government, New York State, the Port Authority of New York and New Jersey, and the City of New York are outside the definition of a covered employer. Beyond that, the chapter does not reach work already covered by the McNamara-O'Hara Service Contract Act, Labor Law Article 9 or Article 19-D, Public Service Law section 42-A, Real Property Tax Law sections 421-a, 467-a, 467-m or 485-x, Administrative Code sections 6-109.1, 6-130 or 10-172, or a Port Authority compensation standard[1]. The 421-a and 467-a carve-outs matter for residential portfolios, where a building may already sit under a prevailing wage regime.
What scheduling system changes does the NYC guard wage law require?
Five requirements fall out of the law and the schedule it points to, and most security scheduling systems weren't designed to handle them.
1. Rate classification per guard, per shift
The classifications turn on certification and armed status, not on how long someone has been on the payroll. An uncertified unarmed guard is at $18.87 an hour anywhere in the first 36 months. A colleague who has twelve months in and holds the F-01, F-03 and F-04 certifications plus Building Evacuation Supervisor training and the two-hour customer service module is at $22.20. An armed guard at the same site is at $33.70[2].
That is a harder thing to automate than a tenure ladder, and it is where a system built on a hire-date rule will quietly get it wrong in both directions. A guard who earns a certification mid-week changes rate mid-week. A guard who has been on site for three years and never certified does not. The system has to hold certification state per guard, date it, and apply it to the shift, because the wrong classification is an underpayment, and an underpayment carries double the shortfall in liquidated damages on top of the shortfall itself[1].
Tenure still matters, but it is measured in a way payroll systems rarely model. Months of employment count service with the employer or at the facility, whichever is greater[2]. Win a building from another contractor and the guards you inherit bring their time at that address with them.
2. Supplemental benefits tracking
The supplemental benefit rate is $8.47 an hour through December 31, 2026, and $8.77 from January 1, 2027. The full rate is identical across all three classifications. The reduced new-employee rates are not, and that asymmetry is where a supplement gets underpaid. They appear under exactly two titles, the armed guard and the 0 to 36 months unarmed guard: $7.95 for the first 120 days of employment, then $8.03 from 120 days to two years, becoming $8.25 and $8.33 respectively on January 1, 2027. The certified unarmed title carries no reduced rate at all. A guard who qualifies at twelve months is owed the full $8.47 from that moment, even though they are still inside the two-year band that would reduce it in either of the other two classifications[2]. The obligation itself starts January 1, 2029[1].
Two details make this a scheduling problem rather than a benefits problem. The supplement is payable for each hour paid, capped at 40 paid hours per week[2], so hours 41 and beyond accrue wage and overtime but not supplement. And the statutory definition of a supplemental benefit is a list, running from medical and hospital care and pensions through unemployment, life, disability, sickness and accident insurance, apprenticeship costs and other bona fide fringe benefits not already required by law[1]. What you actually deliver against that list has to reconcile to hours worked, which means the hours data has to be right first.
3. Six-year records, and a presumption that runs against you
Records documenting compliance must be retained for six years, kept in their original format, and made available to DCWP during an investigation. The department can also impose a uniform system of records by rule[1].
The consequence of a gap is narrower than it is often described, and still serious. It is not a presumption that you violated the law. It is a presumption on a single point: if DCWP alleges a material fact in a notice of violation, asks for a record relevant to that fact, and you cannot produce it, the fact is presumed true[1]. The presumption is rebuttable, so it shifts what you have to prove rather than deciding the case.
"The failure of a covered security guard employer to maintain, retain, or produce a record ... creates a rebuttable presumption that such fact is true."Administrative Code § 20-1607(b)
4. Annual rate reconfiguration
DCWP must post the applicable minimum wage, paid time off and supplemental benefit levels no later than September 1, 2026, and annually after that[1]. For this first cycle the City has said what the posting will carry: the minimum wage requirement that takes effect January 1, 2027[3]. The statute itself fixes only the deadline and says nothing about when a posted rate begins to apply, so whether later September postings track the following January is not guaranteed anywhere in the chapter. Reading that pattern forward is our inference, not a rule the City has published. The Comptroller schedule adds a second calendar to plan against, running July to June with steps on January 1, 2027 and May 1, 2027[2].
Either way the system requirement is the same. Rates change on dates that are known in advance and do not line up with the calendar year, so you need effective-dated configuration: the ability to stage a rate with a start date and have it activate without touching schedules already published.
5. Multi-jurisdiction compliance stacking
Start with the jurisdiction you are already in, because the Comptroller's guard schedule carries an overtime rule of its own: time and one half after an eight-hour day, and time and one half after 40 straight-time hours in a week[2]. Daily overtime is often filed mentally under California. For guards on this schedule it is a New York City obligation, and a twelve-hour post generates four hours of premium before any weekly threshold is reached.
Then add the footprint. A guard working Monday in Manhattan and Wednesday in Newark needs two rule sets applied automatically. California requires overtime after eight hours in a workday and double time after twelve[8]. Washington's minimum wage is $17.13 an hour, effective January 1, 2026[9]. New York City's guard rates now sit on top of whatever else applies at each site.
The system must apply the correct jurisdiction's rules to every assignment, per guard, per site, per shift. This is not a spreadsheet problem but a system architecture problem that requires jurisdiction-aware scheduling at the platform level.
How will NYC enforce the Security Guard Wage Law?
DCWP enforces the chapter, and the two City bodies that estimated the cost of the enforcement work do not agree on its size. The Mayor's Office of Management and Budget put it at 41 staff and $6,033,000 a year in personal service costs, with $4,070,000 in the first year and $22,232,000 across four years[10]. The Council's Finance Division put it at 14 staff and $3,230,969 in fiscal 2027, and said plainly that it considers a number of the positions OMB assumes, particularly the research analysts, unnecessary[11]. Both figures are projections attached to the bill rather than money appropriated to a budget line, and both put the first affected fiscal year at 2027.
Two things widely reported about enforcement are not in the enacted law. A Security Guard Advocate and a dedicated DCWP division of security were in the bill as introduced in September 2025[7]; neither survived into Local Law 61, which also dropped the training standards its original title carried[1][4]. If you are looking for the office to call, it is DCWP.
The complaint routes run on two different clocks, and conflating them is easy. A guard has two years to file a complaint with DCWP, measured from when they knew or should have known of the violation, and six years to bring a civil action in court[1]. DCWP keeps a complainant's identity confidential unless disclosure is necessary to resolve the investigation or required by law, and will notify the complainant first where practicable[1]. A guard does not have to go to DCWP before going to court, and a prevailing plaintiff is awarded attorney's fees and costs[1].
The money runs on three tracks[1]:
| Exposure | Amount |
|---|---|
| Civil penalty | $500 for a first violation, up to $750 for a second within two years, up to $1,000 for each one after that, imposed per covered guard and per instance |
| Underpayment | The full underpayment plus interest, plus an additional amount equal to twice the underpaid wages or benefits as liquidated damages |
| Retaliation | $500 for each violation not involving termination, $2,500 for each violation involving termination, plus rescission of discipline, reinstatement and back pay |
The per-guard, per-instance multiplier is the part worth modeling. A single misclassified rate applied across 40 guards for a year is not one violation. And the retaliation figure is $500, not $2,500, for anything short of termination, which is where a schedule change made in response to a complaint would land: reducing a guard's hours or pay is named in the statute as an adverse action, as is transferring them to a worksite a reasonable person would consider less desirable[1].
One provision deserves a place in your discipline workflow rather than your pay logic. Termination or discipline within 90 days of a guard exercising rights under the chapter, helping someone else do so, or telling anyone about those rights, raises a rebuttable presumption that it was retaliation[1]. That makes the sequence and timestamp of a disciplinary action evidentiary.
What does this mean for security operations?
Whether this becomes a template elsewhere is the open question. 32BJ SEIU, which campaigned for the law, calls it the city's first law setting minimum compensation for private sector workers who are not on a city contract since 1964[6]. That framing comes from the campaign, but the mechanism it describes is real and portable: rather than legislate a rate, the law borrows one that a city agency already publishes and maintains for its own contractors.
The cost side has been estimated publicly, though not by anyone neutral. Amanda DeAlmeida, executive vice president of the contractor Building Security Services, put the increase for 24-hour coverage at a single building at $60,000 to $70,000 a year, and said a guard in the city generally earns about $18 an hour today[12]. That is one operator's read on their own book, not a study, and a firm already paying schedule rates would see less.
The operational burden is a separate problem from the cost. Supporters of the bill cited a 77 percent annual turnover rate in the industry[5], a figure that comes from the campaign for the law rather than from an agency. Take it as directional and the implication holds: a workforce that churns at anything near that rate is one where classification is decided constantly, for new guards, on their first shift, and where an FDNY certificate earned in month thirteen has to reach payroll before the next pay period closes.
Which is a records problem as much as a pay problem, and the two are linked by the six-year retention rule. The version of this that goes wrong is not usually a company deciding to underpay. It is a certification recorded in a training folder and never reflected in a rate, or a rate corrected going forward with nothing showing when it was wrong or who changed it, three years before an investigator asks.
WorkAxle is built for that gap. Licenses and certifications are tracked in effective-dated fields, and certifications are checked against the site, client and role a guard is being assigned to, which is the same mechanism a classification that turns on F-01 through F-04 needs. The labor rules themselves sit in a no-code rule engine that a customer's own team configures per site, so a New York City post can carry the guard schedule's classifications and its eight-hour daily overtime while a site under no comparable rule inherits nothing it shouldn't. Because the rules are configuration rather than a development ticket, a September posting and a January step are a scheduled change instead of a scramble. And every assignment, credential status and override is logged with a timestamp, which is the record the presumption in section 20-1607(b) asks you to produce, six years later, about a shift nobody remembers.