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New York EPLI: Three-year DHR filing window with a February 2024 transition

New York’s Human Rights Law treats all in-state employers as employers, subject to specific statutory provisions. State Division of Human Rights complaints for acts on or after February 15, 2024 generally have a three-year period; earlier acts retain the prior one-year period, except employment sexual-harassment claims already had three years. The administrative route also affects later court options. 1,2

What Is Employment Practices Liability?

EPLI can help pay covered defense costs and losses when applicants or workers allege discrimination, harassment, wrongful termination or other workplace wrongdoing. If you employ people, check the claim definition, defense costs and prior acts. Read the national Employment practices liability guide.

New York Requirements

RequirementDetails
DHR filing windowThree years for alleged discriminatory acts on or after February 15, 2024; before that date, generally one year, with three years for sexual harassment in employment. 1,2

What to Watch for in New York

  • Use the date of the alleged act

    The current statute prints both the former and amended §297(5) text; the Governor’s February 14, 2024 notice states the three-year period applies to incidents on or after February 15, 2024. A pre-transition act may have a shorter period, so preserve the event dates and promptly ask about policy notice. 1,2

  • The state statute has no general small-employer floor

    Executive Law §292(5) says employer includes all employers within the state, while its definition and related provisions retain distinct rules for specific public or other entities. Do not use the federal 15-employee threshold as a shortcut for the New York statute; check the actual employer and claim. 1

  • The administrative filing can affect a court route

    Executive Law §297(9) generally conditions a separate court action on whether the person has already filed with the Division or a local commission, while listing exceptions and an option to request annulment before a hearing. Ask counsel to coordinate forum decisions and ask the insurer whether its notice requirements begin with the administrative filing. 1

Who Regulates Insurance in New York

New York State Department of Financial Services

New York DFS supervises insurance companies and producers, administers insurance law and accepts consumer complaints about property and casualty policies, including commercial insurance. 3,4,5,6

Surplus-lines tax and stamping office

Reported tax rate: 3.6% of gross premium, less returned premium; ELANY stamping fee is 0.15% through 2026 and 0.17% for policies incepting on/after Jan. 1, 2027 When New York is the insured’s home state, excess-line tax is 3.6% of gross premium less returned premium. ELANY’s September 20, 2026 bulletin sets a 0.15% stamping fee through December 31, 2026 and 0.17% for policies incepting on or after January 1, 2027; statutory search requirements and guaranty-fund protection depend on the applicable New York excess-line rules. 7,8,9,10

Excess Line Association of New York

Providers With Documented State Licenses

These providers publish a national listing for Employment practices liability; the state records document licenses for the entities and roles shown below. Some records rely on company-reported information rather than independent regulator verification. A national listing does not confirm the product is available in New York. Check the regulator’s license lookup and confirm state availability for your business when requesting a quote.

  • CoalitionCoalition Insurance Solutions, Inc.Insurance producer, Surplus-lines broker · checked 2026-09-28Coalition’s license page lists producer and surplus-lines licenses for Coalition Insurance Solutions, Inc. in all 50 states and the District of Columbia. The page separately lists insurers; this record covers the brokerage entity only. 12
  • CorgiCorgi Insurance Services, Inc.Insurance producer · checked 2026-09-28Corgi’s company producer-license table lists 50 jurisdictions: 49 states and the District of Columbia, including DC license 3003091619. New Mexico does not appear in the table and is not included here; the omission does not establish that Corgi is unlicensed there. The company-reported table has no stated as-of date and does not establish product availability. 13
  • TechInsuranceSpecialty Program Group LLCInsurance producer · checked 2026-09-28TechInsurance’s current licensing page names Specialty Program Group LLC / SPG Insurance Solutions and lists state license numbers, but labels Rhode Island “Individual licenses” rather than identifying a license for the named agency. RI is omitted because this disclosure does not establish agency authority there; this is a search limitation, not an assertion that the company is unlicensed. The remaining state entries are company-reported and are not an insurance product availability map. 15
  • VouchVouch Specialty Insurance Services, LLCInsurance producer, Surplus-lines broker · checked 2026-09-28Vouch’s licenses page, effective January 16, 2025, lists producer licenses in all 50 states and DC. Its separate surplus-lines table includes Idaho number 870820, while a footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses. Because those statements conflict for Idaho, this record keeps Idaho producer-only and does not treat the table number as established agency surplus-lines authority. The page is company-reported and does not establish product availability. 16

Questions to Ask Before You Buy in New York

  1. Does the policy’s claim definition include a Division or local human-rights complaint before suit?
  2. How should the business report an allegation involving conduct before February 15, 2024 versus later conduct?
  3. Does the organization’s New York employer structure have any distinct public-entity or statutory exception?
  4. Who evaluates whether to pursue an administrative response, request annulment, or move to court?

Employment Practices Liability in New York: FAQ

When did New York extend most DHR complaint periods to three years? 1,2

The amended three-year period applies to alleged acts on or after February 15, 2024. The prior one-year rule remains for earlier acts, except employment sexual-harassment complaints already had a three-year period. 1,2

Does the three-year statute mean an EPLI claim can wait three years to be reported? 1

No. The law’s complaint limit and the policy’s reporting deadline are different. Check the policy’s claim definition, notice timing, and applicable policy period when any written demand or agency filing arrives. 1

Employment Practices Liability in Other States

Other Coverage in New York

Sources

  1. New York Executive Law, Article 15, Human Rights Law. New York State Division of Human Rights; §292(5), p. 5 (employer definition); §297(5), p. 46 (effective versions); §297(9), pp. 46–47 (election of remedies). Accessed 2026-09-28.
  2. Governor Hochul Announces New Statute of Limitations for Unlawful Discrimination. New York State Governor’s Office; Published Feb. 14, 2024; transition: three years for acts on/after Feb. 15, 2024; earlier incidents generally one year except workplace sexual harassment. Accessed 2026-09-28.
  3. New York State Department of Financial Services. New York State Department of Financial Services; Official regulator homepage. Accessed 2026-09-28.
  4. Who We Supervise. New York State Department of Financial Services; DFS describes insurance oversight and provides links to company and producer searches. Accessed 2026-09-28.
  5. Consumer Complaints. New York State Department of Financial Services; Official portal files insurance complaints for health, life and property/casualty insurance. Accessed 2026-09-28.
  6. New York Insurance Law §2118(d)(1). New York State Senate; Current statutory text: 3.6% of gross premiums less returned premium when New York is the insured’s home state. Accessed 2026-09-28.
  7. ELANY Bulletin 2026-20: Notice of Change in Stamping Fee. Excess Line Association of New York; September 20, 2026 bulletin: 0.17% applies to policies incepting from Jan. 1, 2027; endorsements on policies incepting Jan. 1, 2023–Dec. 31, 2026 retain 0.15%; excess-line tax remains 3.6%. Accessed 2026-09-28.
  8. New York Insurance Law §2118. New York State Senate; Excess-line broker duties and filing requirements; §2118(a) due care; exceptions should be applied only where statutory conditions are met. Accessed 2026-09-28.
  9. New York Insurance Law §2118. New York State Senate; Excess-line statutory duties and policies; source is used for placement context. No state-specific guaranty cap/note included. Accessed 2026-09-28.
  10. Licenses. At-Bay; Current producer introduction and state table; At-Bay Insurance Services LLC; P&C and surplus-lines identifiers. Accessed 2026-09-21.
  11. Licenses and Carriers. Coalition; Licenses and Carriers, re-read 22 September 2026: Insurance Licenses table for Coalition Insurance Solutions, Inc., national producer number 18419475, with producer and surplus-lines numbers for all 50 states and DC including California 0L76155, Georgia 196479, Texas 2199630 and 2205589, Pennsylvania 815731 and 817452, Colorado 539028 and Wisconsin 3000108852. Insurance Carriers table naming, with NAIC numbers, Allianz Underwriters Insurance Company 36420, Arch Specialty Insurance Company 21199, Ascot Specialty Insurance Company 45055, Ascot Insurance Company 23752, Aspen Specialty Insurance Company 10717, Chaucer Insurance Company DAC, Coalition Insurance Company 29530, Fireman's Fund Indemnity Corporation 11380, Fortegra Specialty Insurance Company 16823, Lloyd's of London, MSIG Specialty Insurance USA Inc. 34886, MS Transverse Specialty Insurance Company 41807, Steadfast Insurance Company 26387, Vantage Risk Specialty Insurance Company 16275 and Zurich American Insurance Company 16535. Accessed 2026-09-22.
  12. Insurance Producer Licenses. Corgi Insurance; Current complete Insurance Producer Licenses table for Corgi Insurance Services, Inc.; 50 rows covering 49 states and DC (DC 3003091619); no New Mexico row; no NPN or as-of date shown. Accessed 2026-09-28.
  13. About Hiscox US Insurance. Hiscox; Hiscox Insurance Company Inc. NAIC 10200 as Chicago, IL domiciled insurer admitted or licensed in all 50 states and D.C.; Hiscox Inc. as general agent and Lloyd’s coverholder for Syndicates 33 and 3624; surplus-lines placements through licensed surplus-lines brokers; A.M. Best rating statement. Accessed 2026-09-16.
  14. Insurance Licenses by State. TechInsurance; Current state table; identifies TechInsurance as a division of Specialty Program Group LLC d/b/a SPG Insurance Solutions; lists DC 3000041536 and labels Rhode Island “Individual licenses,” without an agency license number. Accessed 2026-09-28.
  15. Licenses. Vouch; Effective 16 January 2025: Vouch Specialty Insurance Services, LLC, NPN 19926463; P&C table (50 states and DC); surplus-lines table includes Idaho 870820; footnote says Georgia and Idaho do not issue agency-level surplus-lines licenses; Idaho retained as producer-only due to conflict. Accessed 2026-09-15.

Updated .

This guide is informational and does not determine whether a policy is available or meets your needs. Editorial policy. To suggest a correction, contact Spot with a supporting source.

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