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Resource: Which States Require Sexual Harassment Training?

Six states mandate harassment training for private employers and three more require it in specific cases. Thresholds by state, and where Empath fits.

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Six states require private employers to train employees on preventing sexual harassment: California, Connecticut, Delaware, Illinois, Maine, and New York. The trigger is headcount, and it is lower than most employers expect. New York and Illinois set no minimum at all, so one employee creates the obligation. Three other jurisdictions require training only in specific situations, two cities impose stricter rules than their states, and no other state requires it of private employers.

This is research, not legal advice.

Empath is a training platform, not a law firm. This article is a reference summary of publicly available state, city, and federal requirements, compiled by Empath Partner Success and verified on August 21, 2026. It is not a compliance assessment. Empath maintains this summary, but the underlying laws are not ours and they change without notice. Confirm your obligations with your own legal counsel before making a compliance decision.

The six states that cover nearly every employer
State Applies at Who must be trained How often
New York 1 employee Everyone, including part time and seasonal Annually
Illinois 1 employee Everyone. Bars and restaurants get an extra module Annually
Connecticut 3 employees Everyone, 2 hours. Below 3 employees, supervisors only Within 6 months of hire, then every 10 years
California 5 employees Staff 1 hour, supervisors 2 hours Every 2 years
Maine 15 employees Everyone, plus an extra module for supervisors Once, within 1 year of hire
Delaware 50 employees Everyone, plus a supervisor module Within 1 year of hire, then every 2 years

Three things employers get wrong

California counts your entire payroll, not just your California staff. One remote employee in Sacramento at a 40 person company triggers the requirement. Most employers train everyone rather than track it person by person. See the California Civil Rights Department guidance.

Connecticut has no real escape hatch. Below three employees you still have to train supervisors. See CT CHRO.

Maine's training requirement is one and done rather than recurring. Train within a year of hire and you are finished. Maine's poster and written policy rules apply to every employer at any size, and only the training is gated at 15.

Required only in specific situations

These are real mandates, but they depend on what you do rather than how many people you employ.

Washington State. Hotels, motels, retail, security guard firms, and property services contractors that employ an "isolated employee," meaning a janitor, security guard, housekeeper, or room service attendant who works at least half their hours with nobody else present. Any size. Isolated employees must be trained before they first work alone. As of January 1, 2026, all managers and supervisors at covered employers must be trained at least annually. See Washington L&I.

Virginia. Only companies holding a state government contract over $10,000 that employ more than five people. Annual training for all supervisors and employees serving Virginia. See Va. Code § 2.2-4201.

Washington, D.C. Employers of tipped wage workers only. Within 90 days of hire, then every two years. Managers must attend in person, and the trainer has to be certified by the DC Office of Human Rights.

Two cities are stricter than their states

Chicago. Any employer with a Chicago business facility or license, at any size. Every year: one hour of harassment training plus one hour of bystander intervention for every employee, and two hours for supervisors. This is the strictest municipal rule in the country. See City of Chicago.

New York City. Employers with 15 or more employees. Annual training for anyone working 80 or more hours a year over at least 90 days, including interns. Must cover bystander intervention. Completion records with signed acknowledgments must be kept for three years. See NYC Commission on Human Rights.

All 50 states and DC
State Required of private employers? Threshold
Alabama No  
Alaska No  
Arizona No  
Arkansas No  
California Yes 5+ employees
Colorado No. Policy required, not training  
Connecticut Yes 3+, supervisors below that
Delaware Yes 50+ employees
District of Columbia Only for tipped worker employers  
Florida Government employees only  
Georgia No  
Hawaii No. Encouraged  
Idaho No  
Illinois Yes 1+ employee
Indiana No  
Iowa No  
Kansas Government employees only  
Kentucky No  
Louisiana Government employees only  
Maine Yes 15+ employees
Maryland No  
Massachusetts No. Policy required at 6+  
Michigan No  
Minnesota No  
Mississippi No  
Missouri No  
Montana No  
Nebraska No  
Nevada Government employees only  
New Hampshire No  
New Jersey Government employees only  
New Mexico Public school personnel only  
New York Yes 1+ employee
North Carolina Government employees only  
North Dakota No  
Ohio No  
Oklahoma Government employees only  
Oregon No. Policy required, not training  
Pennsylvania Government employees only  
Rhode Island No. Encouraged  
South Carolina No  
South Dakota No  
Tennessee Government employees only  
Texas Government employees only  
Utah Government employees only  
Vermont No. Policy and poster required  
Virginia Only state contractors More than 5 employees plus a $10,000 contract
Washington Only certain industries Any size
West Virginia No  
Wisconsin No  
Wyoming No  

"Government employees only" means the state trains its own workforce. Private employers in those states have no training obligation.

No mandate is not the same as no exposure

In every state, having trained your people is what lets you argue you took reasonable care when a claim lands. New Jersey is the clearest example: no statute requires training, but New Jersey courts effectively expect it. The EEOC takes the same position federally.

What healthcare and financial services change

Financial services

Neither FINRA, the SEC, the OCC, the FDIC, nor the Federal Reserve requires harassment training. FINRA's continuing education requirement covers securities products and conduct, not workplace behavior. As far as our research found, the state table above is the whole picture for financial services employers, and this is exactly the kind of question to put to your own counsel rather than take our word for.

What finance does have is a reporting consequence. When you terminate a registered representative you must file a Form U5 within 30 days stating why, and it becomes a permanent public record in BrokerCheck. A harassment termination follows that person, and getting the wording wrong generates defamation claims.

The federal contractor rationale is also gone. Executive Order 11246 was revoked in January 2025, and race and sex affirmative action programs had to be disbanded by April 21, 2025. Only Section 503 for disability and VEVRAA for veterans remain, and neither requires harassment training. See the Congressional Research Service.

Healthcare

Healthcare employers already run mandatory annual training, but the subject is workplace violence rather than harassment. These are different obligations.

  • The Joint Commission has required workplace violence prevention training since January 1, 2022 for all accredited hospitals and critical access hospitals: on hire, annually, and whenever the program changes.
  • CMS told state surveyors in a November 2022 memo that hospitals can be cited under the Conditions of Participation for failing to prevent or respond to workplace violence. That puts Medicare participation at risk.
  • Academic medical centers inherit Title IX and Clery/VAWA obligations, which do require harassment prevention programming for all new employees.
  • Research grants carry reporting duties. NSF requires notice within 10 days of a harassment finding against a principal investigator, and NIH within 30 days of discipline or removal. See NSF notification requirements.

Training vendors often bundle workplace violence and harassment together. A hospital assuming its annual workplace violence module satisfies Illinois's annual harassment requirement would be wrong. Confirm the two are assigned separately.

The second California requirement most employers miss

Since July 1, 2024, nearly every California employer, not only healthcare, must maintain a Workplace Violence Prevention Plan and deliver interactive training on it every year. This is separate from harassment training and applies at almost any headcount. See Cal/OSHA.

A California employer runs two clocks:

  1. Harassment training, every 2 years, at 5 or more employees
  2. Workplace violence training, every year, at nearly any size

New York has a similar rule for retailers with 10 or more retail employees, effective June 2, 2025.

Pending changes to watch
  • New York passed a bill in May 2026 (A368A) that would add a signed employee acknowledgment and seven days' notice before you change your policy. Check its status before your next New York cycle.
  • Cal/OSHA is drafting a formal workplace violence standard due by December 31, 2026. The existing requirement stays enforceable until then.
Using this in Empath

Empath's catalog includes third party content from Inspired eLearning, which covers security awareness and compliance topics and includes workplace safety and sexual harassment prevention material. Many partners do not know it is already available to them.

Compliance training only counts if you can prove it happened. Several of the rules above require documentation. New York City demands three years of completion records with signed acknowledgments, and Washington requires training records be produced to L&I on request.

  • Check the in platform catalog before you buy training elsewhere. The public PDF catalog trails the platform by up to a month and does not reflect everything in your tenant. See Where do I find the Empath course catalog.
  • Assign the course rather than leaving it published. An unassigned course can be watched, but no progress tracks, knowledge checks are disabled, and nothing appears in reporting. See Do I have to assign courses in Empath and How to assign a course in Empath.
  • Group multiple required pieces into a pathway where a jurisdiction requires more than one, such as Chicago's harassment training plus bystander intervention, or a state that adds a separate supervisor module. Assigning the pathway assigns everything inside it. See Understanding lessons, courses, and pathways.
  • Expect third party courses to behave differently from native Empath video. Inspired eLearning content is delivered as SCORM, which means the original author controls navigation, progress indicators, and completion rules, and some courses must be finished in one sitting or progress is lost. See How video playback works in Empath.
  • Set due dates against the legal deadline rather than the calendar quarter. Delaware and Maine run one year from hire, and DC runs 90 days.
  • Keep workplace violence and harassment as separate assignments. They are different obligations and one course does not satisfy both.
  • Track completion in Learning Progress, which reports by assigned content rather than by person. See How to use the Learning Progress dashboard.

A warning about free state provided training

Several states publish their own free training and it is tempting to load it into your platform. California prohibits this. The Civil Rights Department states that its courses may not be reproduced, distributed, or loaded into an employer's own e-learning platform. See CRD Sexual Harassment Prevention Training.

If you use California's free course, employees complete it on the state's own site and you track completion outside your platform. Using licensed course content inside Empath keeps assignment, due dates, and completion records in one place, which matters when New York City asks for three years of signed acknowledgments.

If you resell training through Empath Grow

Grow partners can add premium third party catalogs, including Inspired eLearning, and allocate them to individual client organizations. If you support clients in the jurisdictions above, this table is the starting point for deciding which clients need which catalog. See Premium catalogs available in Empath Grow and How to allocate premium catalogs to a client.

Support

Empath support can help you find, assign, and report on training inside the platform. We cannot tell you what your legal obligations are.

If someone in your organization can access Empath, use the in-app chat bubble.

If you cannot access Empath at all, email support@empathmsp.com.

Include the affected member's email, what you were trying to assign, what you expected to happen, what happened instead, the exact error text, and a screenshot.

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Scope and verification

Published and verified August 21, 2026, against the sources listed below.

State, city, and industry requirements change frequently, and several rules described here changed during 2025 and 2026. Requirements can also turn on facts specific to your business, including where your employees physically work, what industry you operate in, and what contracts you hold. We make no guarantee that this summary is complete or that it remains current after the verification date above.

If you are an Empath partner using this to advise managed clients, pass along the same caution. Those clients should confirm their obligations with their own counsel.

Sources