On December 21, 2015, the New York City Commission on Human Rights (the “Commission”) issued enforcement guidance (the “Guidance”) regarding discrimination on the basis of gender identity or expression. The Guidance explains that under the New York City Human Rights Law (“NYCHRL”), which prohibits discrimination on the basis of “gender identity, gender expression, and transgender status” or for being intersex, gender discrimination occurs whenever one is treated “less well than others on account of their gender.”