On 6 December, New York City Mayor Bill de Blasio announced a first-in-the-nation vaccine mandate covering all private sector workers in NYC that will take effect on 27 December 2021. According to Mayor de Blasio, the mandate will cover approximately 184,000 businesses.

NYC is set to publish guidelines for employers on 15 December, which will provide employers with less than two weeks to implement and enforce the new mandate. Although we do not yet know the full scope of the new requirement, we anticipate that there will be few exceptions. We also anticipate that the mandate will be challenged in the courts. Mayor de Blasio announced that the mandate will apply to all in-person employees, and those employees will not have the option of getting regularly tested in lieu of vaccination. Employees must have at least one dose of the vaccine by 27 December.