Not legal advice — please read before you publish or act on this This article summarizes New York City's Safe Hotels Act in plain language for hotel owners and managers. It is general information, not legal advice, and it is not a substitute for reviewing the law with an attorney or the NYC Department of Consumer and Worker Protection (DCWP). Part of the law is currently being challenged in court, and enforcement guidance can change. Information here reflects our research as of September 2026. Before you make a staffing or licensing decision, confirm the current rules directly with DCWP or your own counsel.

If you own or manage a hotel in New York City, you have likely heard about the Safe Hotels Act, the law that requires hotels to be licensed and changes who can clean your rooms and staff your front desk. It has been in effect since May 3, 2025, and one of its transition deadlines lands on December 1, 2026 — close enough that it is worth understanding now, even if you already have a license. This guide walks through what the Safe Hotels Act actually requires, who needs a license, which staff you must employ directly, which roles you can still staff through an agency, and the deadlines that matter most.

What Is the Safe Hotels Act?

The Safe Hotels Act is a New York City law, formally an amendment to the city's Administrative Code, that requires hotels to obtain an operating license and meet a set of safety, staffing, and cleanliness standards. New York City Council passed the final version on October 23, 2024, the Mayor signed it on November 4, 2024, and it took effect on May 3, 2025, 180 days later. The law is enforced by DCWP, the same city agency that licenses tens of thousands of other businesses across the city.

Who Needs a Hotel License?

You need a DCWP hotel license if your business operates, owns, leases, or manages a hotel in New York City and controls its day-to-day operations, including employment of the people who work there. This generally covers hotel owners, operators, and management companies.

• The license costs $350 and covers a two-year term.

• Applications are submitted online through the city's Business Toolbox.

• Licenses expire on September 30 of even-numbered years, and DCWP mails renewal reminders roughly three months ahead.

• Your hotel also needs Department of Buildings approval for guests to legally occupy rooms. Operating without a required license can lead to a summons through the city's Office of Administrative Trials and Hearings (OATH) and civil penalties if the charges are sustained.

The Core Employee Rule: What It Means for Staffing

This is the part of the law that affects staffing decisions the most. The Act defines a group of roles as core employees, and for hotels with 100 or more guest rooms, core employees generally must be directly employed by the hotel owner rather than supplied by a staffing agency, contractor, or subcontractor. Core employees include:

• Room attendants

• House persons

• Bell staff

• Door staff Roles the law does not treat as core employees include laundry and valet staff, concierge and reservation agents, engineering and maintenance staff, specialty cleaning roles (such as marble polishers or exterior window washers), parking staff, security staff, spa and gym staff, and all food and beverage workers, including cooks, servers, and bartenders, regardless of who employs them. In practice, that means hotels with 100 or more rooms cannot use a staffing agency for room attendants, house persons, or door and bell staff, unless one of the exceptions below applies. Food and beverage, engineering, specialty cleaning, and similar roles are not restricted by this rule.

Three Exceptions to the Direct Employment Rule

1 Small hotels. Hotels with fewer than 100 guest rooms are not subject to the direct employment requirement, and can continue contracting with staffing agencies for core roles. 2 The single hotel operator exception. A hotel owner may retain one hotel operator that directly employs the core employees and manages all hotel operations involving them. In that case, the owner itself does not need to be the direct employer. 3 Existing contracts. Contracts signed before May 3, 2025 can continue for a limited transition period, described below.

Key Deadlines Hotel Owners Should Know

Date What it means May 3, 2025 The Safe Hotels Act took effect. Hotels needed a license to keep operating, and the core employee rule began applying to new staffing arrangements. September 30 (even Hotel licenses expire and must be renewed for another two-year term. years) December 1, 2026 Pre-May 3, 2025 staffing contracts with no fixed end date (open-ended or “evergreen” agreements) must end by this date. A contract with a set end date can generally run through that date instead. February 22, 2026 The related Hotel Junk Fees Rule took effect, banning hidden fees disguised as destination or resort fees. February 2027 Credit card hold disclosure requirements under the Junk Fees Rule take effect. If your hotel is relying on the existing-contract exception and your agreement has no fixed end date, December 1, 2026 is the date to plan around. Confirm your contract's terms with your staffing partner and your attorney well before then.

Other Requirements Under the Act

Licensing and staffing get the most attention, but the Safe Hotels Act includes several other requirements:

• Continuous front desk coverage. At least one employee must be scheduled to cover the front desk at all times and be able to confirm guest identity at check-in. At large hotels, a trained security guard may cover the overnight shift instead.

• Panic buttons. Core employees who enter occupied guest rooms must be given a panic button at no cost to them.

• Human trafficking training. Core employees must receive human trafficking recognition training within 60 days of starting work, under New York General Business Law section 205.

• Daily room cleaning. Guest rooms must be cleaned daily, with fresh towels and linens, before a new guest checks in. A guest may decline daily service, but the hotel cannot offer a discount or incentive for declining.

• No short stays. Bookings under four hours are generally not permitted, with an exception for airport hotels. Two related rules are also worth knowing. The Hotel Service Disruption Act requires hotels to notify guests within 24 hours of a significant service disruption and allow penalty-free cancellations. The Hotel Junk Fees Rule, effective February 22, 2026, bans hidden fees disguised as destination or resort fees, with credit card hold disclosure rules following in February 2027.

Enforcement Is Active

DCWP has been actively enforcing the law. In March 2026, the agency issued compliance warnings to more than 760 licensed hotels citywide as a reminder of these obligations. If your hotel already holds a license, that is a sign DCWP is watching for ongoing compliance, not only the initial licensing step.

A Pending Legal Challenge

The law is not free of controversy. In September 2025, a coalition called Hotel Owners of New York, Inc. filed a legal proceeding against DCWP, arguing that some of the agency's implementing rules exceeded its authority, including certain records requirements and penalty provisions. As of the most recent information available, the case was still pending in New York State Supreme Court and had not been decided. This does not change your obligations today, but it means guidance could shift. If the outcome affects your hotel's licensing or staffing plans, your attorney is the right person to advise you on next steps.

What This Means for Staffing

For hotel owners weighing their staffing options, the practical takeaway is:

• If your hotel has 100 or more rooms, plan to directly employ room attendants, house persons, and door or bell staff, unless you use the single-operator model or you are still inside a qualifying existing contract.

• If your hotel has fewer than 100 rooms, you are not subject to the direct employment rule and can continue to use staffing agencies for these roles.

• Roles outside the core employee definition, including food and beverage, after-construction cleaning, and DHS cleaning services, are not restricted by this rule for hotels of any size.

• Doorman staffing for non-hotel properties, such as residential buildings and offices, is a different market and is not covered by this hotel-specific law. See our doormen staffing page for that market. We go deeper on the small-hotel exemption and on exactly which roles hotels of any size can still staff through an agency in two follow-up articles on this blog.

How Labor Solution Can Help

Whatever size your property is, Labor Solution can help you staff the roles the Safe Hotels Act does not restrict, including food and beverage and kitchen staff, after-construction cleaning, and DHS cleaning services. If your hotel has fewer than 100 rooms, or you are working through the single-operator model, we also support hotel housekeeping and doorman staffing needs. Get a quote or contact us to talk through what fits your property, or call us at (877) 261-7377. For background on why many hotels use outsourced staffing where the law allows it, see our article on the benefits of outsourcing hotel staffing.

Frequently Asked Questions About the NYC Safe Hotels Act

Does every NYC hotel need a Safe Hotels Act license?

Yes. Any business that operates, owns, leases, or manages a hotel in New York City and controls its day-to-day operations needs a DCWP hotel license, regardless of hotel size. The size of the hotel affects the staffing rules, not the licensing requirement.

What counts as a core employee under the Safe Hotels Act?

Core employees are roles related to housekeeping, front desk, and front service: room attendants, house persons, and bell or door staff. Food and beverage workers, engineering and maintenance staff, and specialty cleaners are not core employees.

Can a small NYC hotel still use a staffing agency for housekeeping?

Hotels with fewer than 100 guest rooms are not subject to the direct employment requirement for core employees, so they can generally continue using staffing agencies for these roles.

What happens to existing staffing contracts?

Contracts signed before May 3, 2025 with a fixed end date can generally run through that date. Open-ended contracts with no fixed end date must end by December 1, 2026, based on the most recent guidance available.

Is the Safe Hotels Act being challenged in court?

Yes. A hotel industry coalition filed a legal proceeding against DCWP in September 2025 challenging parts of the implementing rules. As of the most recent information available, the case was still pending, so hotel owners should confirm current status with their attorney.

Can hotels still outsource food and beverage or specialty cleaning services?

Yes. Food and beverage staff, after-construction cleaning, DHS cleaning services, and other non-core roles are not restricted by the direct employment rule, regardless of hotel size.

Final Thoughts

The Safe Hotels Act changed how New York City hotels handle licensing and core staffing, but it left plenty of room for outsourcing outside the core employee definition, and it carved out an exemption for smaller properties. Know which category your hotel falls into, track the December 1, 2026 deadline if it applies to you, and confirm the current legal picture with your own counsel or DCWP before making staffing changes.