Laying off employees isn’t a simple matter of notifying employees and moving forward. In fact, recent amendments to state Worker Adjustment and Retraining Notification (WARN) laws suggest an expansion of employer obligations for layoff reporting and worker protections. Across the US, regulatory frameworks continue to evolve, and it’s critical to stay ahead of these changes to protect your organization from compliance risks.
New York’s recent update to its WARN Act is a powerful example of how tighter layoff regulations can shift employers’ approach to reductions in force (RIFs) nationwide.
New York WARN Updates: Two Changes that Hint at What’s Next
In March 2025, New York became the first state to require employers to disclose whether artificial intelligence (AI) or automation contributed to a layoff decision. The updated WARN notice form now includes a checkbox asking if “technological innovation or automation” played a role in job reductions. Employers that check the box must also specify the technology involved, such as AI or robotics. Currently, this requirement is for data collection and statistical analysis only. However, history shows that small reporting changes often foreshadow larger compliance mandates. As AI adoption accelerates, you can expect other states to follow New York’s example.
In June 2025, the New York State Department of Labor adopted broader amendments to the state WARN law. These updates required employers to include remote employees in the number of employees that trigger WARN notifications, notify local schools and public safety authorities of layoffs, and provide more information about affected employees. While less headline-grabbing than the AI disclosure rule, these changes drive home the reality that states are actively tightening layoff laws to keep pace with the evolving workplace.
Increased Regulatory Requirements Rise Alongside Surging Layoffs
Layoff activity has increased in recent years, and declining business performance isn’t always the cause. In fact, many healthy companies now announce layoffs even as they report strong earnings and expand in other areas.
Through October 2025, over one million jobs have been affected by layoffs, a significant increase over the nearly 670,000 layoffs during the same period in 2024. This trend seems to show no signs of slowing, as one survey found that 60% of employers expect to implement layoffs in 2026.
Transparency and Accountability Take Center Stage
As layoffs have grown, so has state regulatory oversight. Employers conducting layoffs today must navigate federal WARN rules and a patchwork of state “mini-WARN” Acts. In addition to New York, thirteen states—including California, Illinois, and New Jersey—have their own versions of WARN that impose stricter thresholds and longer notice periods than federal law.
New York’s checkbox reflects a broader push to hold employers accountable and track the impact of technology-driven workforce changes, and other states are doing the same. For instance, starting in 2026, Illinois and Colorado will enforce laws governing the use of AI in hiring, promotions, and disciplinary actions.
AI isn’t the only reason for expanding layoff regulations. State and local governments are also demanding greater transparency because detailed layoff data helps them better plan for workforce support programs and economic redevelopment initiatives.
What Employers Should Do When Laying Off Employees
Layoffs are complex, not just operationally, but legally and reputationally. Given that regulations evolve and workforce expectations shift, it’s essential to develop a proactive layoff strategy that balances compliance, transparency, and employee care. To achieve these goals, take the following actions when laying off employees:
Stay Ahead of Compliance Shifts
A recent SHRM survey found that more than one in seven HR professionals managed a reduction in force within the past 30 days. Since a future RIF may be on the horizon in your organization, be sure to:
Regularly review federal WARN and state mini-WARN Acts – and engage your legal counsel as appropriate. These laws vary by state and can change quickly, so staying current prevents costly violations.
- Keep an eye on new reporting requirements regarding:
- Layoff reasons, such as AI or automation
- Impacted job categories
- Required notice periods
- The minimum number of affected employees that trigger WARN obligations
Partner with Experts
Legal counsel: Employment attorneys help interpret complex, state-specific WARN rules and ensure your layoff plans meet all notice and reporting requirements. They can also advise on risk mitigation strategies regarding severance agreements and documentation to protect your organization from litigation.
Experienced outplacement providers: Your outplacement services provider supports affected employees with one-on-one career coaching, resume development, and job search tools. Partnering with a trusted provider not only helps employees transition but also signals how your organization treats its people. As Lauren Herring, CEO of IMPACT Group, notes on LinkedIn, how you handle layoffs sends a powerful message to those who stay and those who may join later.
Protect Your Brand and Reduce Risk with a Trusted Outplacement Provider
Compliance missteps amid layoffs can lead to costly penalties and reputational damage. However, by staying ahead of regulatory changes and providing compassionate support to displaced employees, you can manage the risks and maintain organizational integrity.
IMPACT Group’s outplacement services help your employees transition quickly while safeguarding your brand and minimizing legal risk. Contact us to learn more about why so many companies trust IMPACT Group.
For more layoff insights, download our Layoff Checklist.
