- with Senior Company Executives and HR
As we previously reported, Philadelphia passed substantial amendments to its fair chance ordinance, the Fair Criminal Record Screening Standards Ordinance (FCRSSO), which became effective in January 2026. The amendments provided that the Philadelphia Commission on Human Relations could, but was not required to, prepare an updated FCRSSO summary of rights. The Commission has now done so, and the document can be downloaded here.
No press release announcing the creation or publication of the document has been identified, but a banner appeared on the Philadelphia Commission’s home page with a link to the new notice. Now that the notice has been issued, the most conservative approach for employers would be to utilize the updated notice when complying with FCRSSO Section 9-3504.1’s requirement to provide “[a] summary of the Applicant’s or Employee’s rights under the Fair Criminal Record Screening Standards Ordinance,” before rejecting an applicant or employee for a job based on criminal record history.
In addition, employers should also recall that the pre-existing terms of Section 9-3509 of the FCRSSO required employers to “post a summary of the Chapter requirements, in a form to be supplied by the Commission, in a conspicuous place on the employer’s website and premises, where Applicants and Employees will be most likely to notice and read it.” Thus, the most conservative approach would be to utilize the updated notice in those postings.
We have also reached out to the Philadelphia Commission to inquire why the notice website still contains other versions of the posters, including one from 2021 and one from 2024 (which is in English and Spanish), which could lead to confusion, especially since the old versions contain content that conflicts with the requirements of the amendments. In theory, employers should not have to provide these now-outdated posters to employees and applicants. We will update this article if we receive further clarification from the Commission.
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