Philadelphia has released its first guidance on the City’s revised Fair Chance Hiring law. The guidance provides insight into the Commission’s compliance priorities while leaving employers to navigate several key implementation decisions.gettyPhiladelphia employers have spent much of 2026 waiting for answers.When Philadelphia's revised Fair Criminal Record Screening Standards Ordinance took effect on January 6, 2026, many employers expected additional guidance from the Philadelphia Commission on Human Relations. Four months later, the Commission provided its first public roadmap for compliance.The amendments, signed by Mayor Cherelle Parker in October 2025, introduced new restrictions on the use of criminal records, expanded procedural safeguards, and enhanced protections for applicants and employees with criminal histories.One provision drew particular attention from employers and background screening professionals. The amended ordinance authorized the Commission to issue regulations and create forms to help employers comply with the new requirements, including a required notice, a summary of rights under the ordinance, and a statement concerning evidence of error or rehabilitation.As the effective date came and went, many employers expected the Commission to publish additional implementation guidance and compliance resources. Instead, on April 28, 2026, the Commission posted a one-page document titled "Fair Criminal Records Screening Standards Ordinance (FCRSSO) Amendments," which summarizes six key changes made by the law.The publication offers employers their first formal glimpse into how the Commission views implementation of the amendments and provides useful insight into the City's compliance priorities.MORE FOR YOUWhat The Commission PublishedThe Commission's April 28 publication identifies six areas that employers should focus on when evaluating compliance with the amended ordinance.First, the guidance addresses employer notices concerning criminal background checks and states that employers should communicate that any criminal background check will involve an individualized assessment based on the applicant's specific record and the duties and requirements of the position.The guidance also highlights the ordinance's revised limitations on the consideration of criminal records. The publication notes that felony convictions generally remain subject to a seven-year lookback period, misdemeanor convictions are generally subject to a four-year lookback period, and summary offenses may not be considered for employment purposes.Another area of focus is individualized decision making and an employer's obligation to provide sufficient information to enable the Commission to evaluate whether a particular criminal history presents an unacceptable risk in relation to the position at issue.The publication reiterates the importance of rehabilitation evidence and reminds employers that rehabilitation, mitigation, and other relevant circumstances should be considered before a final employment decision is made.Employers should also note the ordinance's strengthened anti-retaliation protections, including the potential presumption of retaliation when adverse action occurs within ninety days of an individual exercising rights under the ordinance.Finally, the publication highlights expanded notice obligations when adverse action is contemplated, including notice of rights, disclosure of the basis for the decision, opportunities to submit evidence of error, rehabilitation, or mitigation, instructions for responding, and notice of the ordinance's ten-day response period.Taken together, the guidance provides employers with a useful roadmap of the Commission's compliance priorities and offers the first public indication of how the City views implementation of the amended law.What Employers ExpectedThe Commission’s publication is noteworthy not only because of what it contains, but also because of what it does not contain.The amended ordinance authorizes the Commission to create forms for use by employers, including a required notice, a summary of rights under the ordinance, and a statement concerning evidence of error or rehabilitation.Many employers interpreted that language as signaling that the Commission would eventually publish model applicant-facing materials that could be incorporated into existing fair chance hiring workflows.That expectation was understandable. Fair chance hiring laws in other jurisdictions often include model notices, summaries of rights, or prescribed language that employers can incorporate into their hiring processes.Philadelphia’s April 28 publication takes a different approach. Rather than providing applicant-facing forms, the Commission published an employer-facing summary of the amendments. As a result, many of the implementation decisions employers hoped would be addressed through model forms remain the responsibility of the employer.One of the most common questions employers have raised concerns the ordinance’s requirement that applicants receive a notice in plain language that includes a summary of their rights under the Fair Criminal Record Screening Standards Ordinance.Philadelphia has not published a model summary of rights or prescribed language that employers can simply incorporate into their existing pre-adverse action processes.As a result, employers must determine how to satisfy the ordinance’s notice requirements using the statute and the Commission’s published guidance. That includes evaluating how they will communicate the rights afforded under the ordinance, including the opportunity to challenge the accuracy of criminal history information, submit evidence of rehabilitation or mitigation, and provide an explanation before a final employment decision is made.What Employers Should Focus On NowAlthough the April 28 notice does not answer every implementation question, it does provide employers with a clearer picture of the Commission's compliance priorities.Candidate-facing communications deserve particular attention. The Commission's guidance states that employers must communicate that any criminal background check will involve an individualized assessment based on the applicant's specific record and the duties and requirements of the position.That statement may be one of the most significant aspects of the guidance because it raises an immediate implementation question: where should that communication appear?Organizations may want to review job advertisements, employment applications, conditional offer materials, and other candidate communications to determine whether updates are appropriate. At a minimum, employers should consider how this aspect of the guidance fits within their current hiring process.Employers should also review how they apply the ordinance's criminal record restrictions. This includes ensuring that conviction lookback periods are calculated correctly and that summary offenses and other prohibited records are excluded from consideration.In addition, employers should evaluate their individualized assessment process. The amended ordinance requires consideration of multiple factors, including the nature of the offense, the time that has passed, the duties of the position, employment history, references, and evidence of rehabilitation. Hiring teams should understand both the legal requirements and how those factors are documented and applied in practice.Finally, employers should review their adverse action procedures to ensure applicants receive the information and response opportunities required by the ordinance before a final employment decision is made. Particular attention should be paid to applicant notices, opportunities to submit evidence of error, rehabilitation, or mitigation, and the ordinance's ten-business-day response period.Parting ThoughtsPhiladelphia’s amended Fair Criminal Record Screening Standards Ordinance has now been in effect for several months, and the Philadelphia Commission on Human Relations has provided its first public implementation guidance.While the April 28 publication does not resolve every compliance question, it provides employers with a clearer understanding of the Commission’s priorities and expectations. Employers should continue monitoring future guidance and developments while reviewing their current practices against both the ordinance and the Commission’s published materials.For employers operating in Philadelphia, the April 28 guidance may not answer every question, but it does provide enough direction to begin evaluating whether existing hiring procedures, applicant communications, and adverse action processes align with the City's expectations.