New York Consolidated Laws

N.Y. Civil Service Law § 204 (2026)

Recognition and certification of employee organizations

✓ current as of May 2026

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§ 204. Recognition and certification of employee organizations. 1.
Public employers are hereby empowered to recognize employee
organizations for the purpose of negotiating collectively in the
determination of, and administration of grievances arising under, the
terms and conditions of employment of their public employees as provided
in this article, and to negotiate and enter into written agreements with
such employee organizations in determining such terms and conditions of
employment.
  2. Where an employee organization has been certified or recognized
pursuant to the provisions of this article, it shall be the exclusive
representative, for the purposes of this article, of all the employees
in the appropriate negotiating unit, and the appropriate public employer
shall be, and hereby is, required to negotiate collectively with such
employee organization in the determination of, and administration of
grievances arising under, the terms and conditions of employment of the
public employees as provided in this article, and to negotiate and enter
into written agreements with such employee organizations in determining
such terms and conditions of employment.
  3. For the purpose of this article, to negotiate collectively is the
performance of the mutual obligation of the public employer and a
recognized or certified employee organization to meet at reasonable
times and confer in good faith with respect to wages, hours, and other
terms and conditions of employment, or the negotiation of an agreement,
or any question arising thereunder, and the execution of a written
agreement incorporating any agreement reached if requested by either
party, but such obligation does not compel either party to agree to a
proposal or require the making of a concession.

Notes of Decisions

Cited in 66 cases (9 in the last 5 years), 1985–2025 · leading case: Kent v. Lefkowitz, 54 N.E.3d 1149 (NY 2016).

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Kent v. Lefkowitz, 54 N.E.3d 1149 (NY 2016). “, 6 NY3d 563, 572 [2006] [emphasis *508 added], quoting Civil Service Law § 204 [2]; see Matter of New York City Tr.”

Cnty. of Chautauqua v. Civil Serv. Employees Ass'n, Local 1000, 869 N.E.2d 1 (NY 2007). “Discussion The Taylor Law empowers and, in fact, requires a public employer to bargain with employee organizations and to enter written agreements governing the terms and conditions of employment (see Civil Service Law § 204 [1], [2]; see also Matter of Professional, Clerical,…”

Stettine v. Cnty. of Suffolk, 488 N.E.2d 75 (NY 1985). · cites it 4× “), they enjoy legislatively protected rights to exclusive representation of their employee members (Civil Service Law § 204), their membership is not voluntary in the customary sense but consists of all public employees within a bargaining unit, a majority of whom have voted to…”

In Re the Arbitration Between Prof'l, Clerical, Technical Employees Ass'n & Buffalo Bd. of Educ., 683 N.E.2d 733 (NY 1997). · cites it 2× “Civil Service Law § 204 — the Taylor Law — empowers, and, in fact, requires a public employer to negotiate collectively with employee organizations and enter into written agreements governing the terms and conditions of employment (Civil Service Law § 204 [1], [2]).”

City of New York v. Patrolmen's Benevolent Ass'n, 924 N.E.2d 336 (NY 2009). · cites it 2× “We subsequently granted leave to appeal ( 12 NY3d 707 [2009]), and now reverse. II. The Taylor Law requires public employers to collectively bargain over “terms and conditions of employment of the public employees” (Civil Service Law § 204 [2]).”

In Re the Arbitration Between Bd. of Educ. of Watertown City Sch. Dist. & Watertown Educ. Ass'n, 710 N.E.2d 1064 (NY 1999). “In addition to imposing these obligations, the Taylor Law permits public sector parties to submit CBA grievances to arbitration (Civil Service Law § 204). This species of arbitration — grievance arbitration — is at issue in this case.”

In Re the Arbitration Between Johnson City Prof'l Firefighters Local 921 & Vill. of Johnson City, 958 N.E.2d 899 (NY 2011). · cites it 2× “Because I believe public policy does not prohibit the arbitration of the "no-layoff" clause in the collective bargaining agreement (CBA) governing the relationship of the parties in this case, and because the majority opinion departs from this Court's commitment to the…”

Bd. of Educ. v. Ambach, 517 N.E.2d 509 (NY 1987). “(Civil Service Law § 204 [3].) Permitting employees to prosecute alleged violations of the agreement beyond the contractual grievance procedure obviously unsettles the finality of grievance determinations that is central to implementation of State policy, and the right to bring…”

Aeneas McDonald Police Benevolent Ass'n v. City of Geneva, 703 N.E.2d 745 (NY 1998). “Under New York’s “Taylor Law” (Civil Service Law, art 14, §§ 200-214), the City, as a public employer, is statutorily obligated to negotiate in good faith with the bargaining representative of its current employees regarding the “terms and conditions of employment” (Civil…”

Mayor of New York v. Council of New York, 874 N.E.2d 706 (NY 2007). · cites it 2× “In sum, the Taylor Law legitimizes and protects agreements collectively bargained between a public employer and a public employee union, whether or not the agreement's terms, or some of them, are also recited in statute or local law ( see Civil Service Law §§ 204, 204-a). The…”

Bd. of Educ. of City Sch. Dist. v. New York State Pub. Emp. Relations Bd., 554 N.E.2d 1247 (NY 1990). “ncerns required, at the very least, that PERB recognize that the requirements are a permissive subject of negotiations, and that the Board need not enter into negotiations unless it chooses to do so! The unions, of course, contend that the disclosure requirements are "terms and…”

Cnty. of Erie v. State, 14 A.D.3d 14 (N.Y. App. Div. 2004). “” That is, an employer’s breach of a CBA provision is remediable through contractual grievance procedures unless the parties agree otherwise, while a charge that an employer has violated the statutory duty to bargain in good faith over a matter outside the terms of a CBA is a…”

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