Philadelphia’s Fair Criminal Record Screening Standards Ordinance has been significantly updated, and employers across the city must now navigate a more detailed set of requirements.
The Philadelphia Commission on Human Relations issued an updated poster on April 28, 2026, tracking amendments that took effect on January 6, 2026.
The ordinance, known as the FCRSSO, was originally signed into law on October 8, 2025, introducing new restrictions on the use of criminal records in hiring decisions.
The Commission has yet to issue guidance clarifying the poster’s legal significance or practical effect, leaving employers to follow the amendments’ plain language notification requirements directly.
A new client intake form was also released on June 12, 2026, identifying the specific notification and other requirements employers must satisfy under the amended ordinance.
Under the updated rules, employers may only consider felony convictions that occurred within the preceding seven years, while misdemeanor convictions are subject to a four-year lookback period.
Summary offences may not be considered at all, and employers must also factor in evidence supporting an applicant’s rehabilitation when making any employment decision involving criminal record information.
Before taking any adverse hiring action based on criminal record information, employers must provide applicants with written notice of their rights, a copy of the criminal history report, and clear instructions on how to submit a response.
Applicants must be given ten business days to provide responsive information before a final adverse decision can be made.
The ordinance contains strong antiretaliation protections, with the investigating agency permitted to presume retaliation if an employer takes adverse action within 90 days of an individual exercising their rights.
The intake form lists specific examples of retaliatory conduct, including withdrawing a conditional offer and then telling other companies that an applicant may be a “troublemaker” because of their criminal record.
Other examples of retaliation outlined in the intake form include refusing to consider applicants for other positions for which they were qualified, or giving a terminated employee a negative reference.
Employers are advised to review and update their individualized assessment procedures, adverse action notification language, pre-hire materials, and job advertisements to ensure compliance.
Training consistent with the Commission’s antiretaliation protections should also be provided to all staff involved in the hiring process, according to guidance published by Jackson Lewis P.C.
The updated FCRSSO poster must be displayed in a conspicuous location on the employer’s premises and on their website to maintain compliance.