Dear David: Hard Copy or Electronic Posters?

Question:
We have remote and on-site employees. Do we have to post hard copies of required labor posters in the workplace, or can we provide only electronic ones on our internal web page for all employees to see?

Answer:
As you have remote and on-site employees, we recommend doing both. In December 2020, the Department of Labor issued Field Assistance Bulletin 2020-07, which permits businesses to share the poster information electronically as a supplement to the requirement to post hard copies. Electronic posting is only allowed as a substitute for physical posters if the following conditions are met: 

1. All the employer’s employees exclusively work remotely; 
2. All employees customarily receive information from the employer via electronic means; and
3. All employees always have readily available access to the electronic posting. 

Note that electronic posting of required labor posters must be as effective as on-site posting. They should be readily accessible without employees needing to ask for permission to view them or where to find them. We recommend sharing in a location where remote employees typically receive other legal notices and important information from your organization. 

Advice provided by Mineral. This Q&A does not constitute legal advice and does not address state or local law. 

David Katz
Vice President
VMA Insurance Services

To send your questions, write to david@visualmediaalliance.org