The Safe Hotels Act (the Act), which went into effect on May 3, 2025, imposes a variety of new requirements on hotel operators in New York City. "Hotel operators" are defined as any person "who owns, leases, or manages a hotel and is in control of the day-to-day operations of such hotel..." Importantly, the Act requires all hotel operators to obtain a license from the Department of Consumer and Worker Protections. The application, which can be completed online, requires hotel operators to disclose personal information about their owners, among other things.
Another significant obligation imposed by the Act is the requirement that hotel owners, either directly or through a single hotel operator, employ core employees, which are defined as those employees "whose job classification is related to housekeeping, front desk, or front service at a hotel" and include "room attendants, house person, and bell or door staff." The foregoing employment requirement does not apply to owners of hotels with fewer than 100 guest rooms. This aspect of the Act was contentious, as hotel operators are concerned it will add add significant costs and does not serve the purpose of the Act, which is to improve safety and address human trafficking concerns.
Whether the hotel is covered by a collective bargaining agreement (and whether that agreement "expressly incorporates") the Act's requirements may impact whether the Act is applicable to a particular hotel. This is a critical issue that operators must account for when ensuring compliance.
Other significant personnel and operational requirements under the Act include the following:
- Hotel operators must schedule at least one employee to provide continuous front desk coverage at all times, except that during an overnight shift, instead of front desk staff, a security guard who is able to assist guests and has undergone human trafficking recognition training may be scheduled instead.
- Hotel operators must clean occupied guest rooms and remove trash daily unless a guest affirmatively declines such services. Further, hotel operators cannot impose fees for such cleaning services or offer discounts or other incentives to forgo daily room cleaning.
- Hotel operators (except for airport hotels) may not accept reservations for a guest room for less than four hours.
- Hotel operators must provide human trafficking recognition training to new core employees within 60 days of the commencement of their employment.
- Hotel operators must provide panic buttons to all core employees whose duties involve entering occupied guest rooms.
The Act also provides whistleblower protections for employees who identify practices that may be a violation of the Act or are a substantial danger to public health or safety.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
