Philadelphia’s updated ‘ban the box’ requirements: Employers get a new checklist

On April 28, 2026, the Philadelphia Commission on Human Relations (PCHR) issued an updated poster regarding the 2026 Amendments to Philadelphia’s Fair Criminal Record Screening Standards Ordinance (FCRSSO) that apparently tracks the amendments that went into effect on January 6, 2026. However, the PCHR has yet to issue guidance clarifying the poster’s legal significance or practical effect, not to mention other guidance on implementation. Consequently, employers should be aware of the specific amendments the PCHR chose to highlight in the poster while simultaneously following the amendments’ plain language notification requirements.

FCRSSO amendments: Key requirements

Signed into law on October 8, 2025, the FCRSSO introduced new restrictions on the use of criminal records, expanded procedural safeguards, and enhanced protections for applicants and employees with criminal histories.

Notice of background check. Employers may notify (but aren’t required to) prospective applicants—including through job advertisements—that they will conduct a criminal background check after any conditional offer of employment, promotion, or re-employment has been made. If they provide such notification, it must state that any consideration of the results of the background check will include an individualized assessment based on the specific criminal record at issue as well as the duties and job requirements of the specific position.