EDIT: Disclosure requirements under Massachusetts’ pay transparency law will take effect on October 29, 2025. Notwithstanding the revised effective date, disclosure and reporting obligations remain the same.
Gone are the days when salary discussions were shrouded in secrecy. Due to shifting workplace standards and expectations, open discussions about pay are the new norm – and in some states and localities, required. While some employers remain untouched by the recent proliferation of pay transparency laws, other employers may be subject to multiple pay transparency laws. To navigate this tangled web the states (and localities) have collectively woven, review this comprehensive list of U.S. pay transparency laws to determine which law(s) apply to your organization.
California
Effective as of January 1, 2023, employers with 15 or more employees must include the pay scale for a position in any job posting. Upon request, employers must provide (1) applicants with the pay scale for the position to which they applied, and (2) employees with the pay scale for their current position.
Colorado
Effective as of January 1, 2021, employers must include in each job posting and job opportunity (1) the actual compensation or salary range, and (2) a general description of benefits. Effective as of January 1, 2024, employers are required to make reasonable efforts to announce each job opportunity to all Colorado employees before a selection decision is made. Following a selection decision, employers must provide certain employees with specific information about the selected candidate.
Connecticut
Effective as of October 1, 2021, employers must provide applicants with the wage range for the position to which they applied at the earlier of (1) the applicant’s request, or (2) before or at the time an offer is made. Employers must provide employees with a wage range for their position upon (1) hire, (2) a change in position, or (3) first request.
District of Columbia
Effective as of June 30, 2024, employers must provide a wage or salary range in all job listings and position descriptions. Prior to the first interview, employers must disclose to applicants the “schedule of benefits, including bonuses, healthcare and other wellness benefits, stocks, bonds, options, equity, and nonmonetary remunerations” they may receive.
Hawaii
Effective as of January 1, 2024, employers with 50 or more employees must include the wage or salary range in certain job listings.
Illinois
Effective as of January 1, 2025, employers with 15 or more employees must include pay scale and benefits information in job postings for (1) positions physically performed in Illinois, and (2) out-of-state positions reporting to a supervisor or office in Illinois.
Maryland
Effective as of October 1, 2020, upon request, employers must provide applicants with a wage range for the position to which they applied. Effective as of October 1, 2024, employers must include in all job postings for positions physically performed in Maryland (1) a wage range, and (2) a general description of benefits and other compensation offered for the position.
Massachusetts
Effective July 31, 2025, employers with 25 or more employees in Massachusetts will be required to disclose pay ranges (1) in all job postings, (2) to existing employees offered a promotion or transfer to a new position, and (3) upon request, to employees for positions held and to applicants for positions applied.
The law also requires employers with at least 100 employees subject to certain EEO reporting requirements to file a pay data report with the Commonwealth, disclosing workplace demographics and pay data by race, ethnicity, sex, and job category. The first round of pay data reports were due February 1, 2025.
Minnesota
Effective as of January 1, 2025, employers with 30 or more employees in Minnesota must include in each job posting (1) the wage or salary range, and (2) a general description of benefits and other compensation offered for the position.
Nevada
Effective as of October 1, 2021, employers must provide interviewed applicants with the wage or salary range for the position. Upon request, employers must provide employees with the wage or salary range for a promotion or transfer if the employee (1) applied for the promotion or transfer, and (2) completed an interview or was offered the position.
New Jersey: State and Local Laws
State: Effective June 1, 2025, employers with 10 or more employees over 20 calendar weeks who conduct business, employ individuals, or take employment applications in New Jersey must disclose in each job posting or transfer opportunity (1) the wage or salary range, and (2) a general description of benefits and other compensation.
For certain promotional opportunities, employers must make reasonable efforts to announce or post the opportunity to certain employees before a selection decision is made. For additional information, see HERE.
Jersey City: Effective as of April 13, 2022 (revised July 6, 2022), employers with at least five employees (including independent contractors) must disclose in postings for jobs, promotions, or transfer opportunities the wage or salary range for the position. For additional information, see HERE.
New York: State and Local Laws
State: Effective as of September 17, 2023, employers with four or more employees must include the compensation range and a job description in postings for jobs, promotions, or transfer opportunities for (1) positions physically performed in New York, and (2) out-of-state positions reporting to a supervisor or office in New York. For additional information, see HERE.
New York City: Effective as of November 1, 2022, employers with four or more employees (including independent contractors) must include a wage or salary range in each posting for jobs, promotions, or transfer opportunities.
Ithaca: Effective as of September 1, 2022, employers with four or more employees in Ithaca must include a wage or salary range in postings for jobs, promotions, or transfer opportunities.
Westchester County: Effective as of November 6, 2022, employers with four or more employees in Westchester County must include a wage or salary range in postings for jobs, promotions, or transfer opportunities.
Albany County: Effective as of February 12, 2023, employers with four or more employees in Albany County must include a wage or salary range in postings for jobs, promotions, or transfer opportunities.
Ohio: Local Laws
Cincinnati: Effective as of April 12, 2020, upon request, employers within Cincinnati with 15 or more employees must provide applicants who receive a conditional offer of employment with the pay scale for the position.
Toledo: Effective as of August 4, 2020, upon request, employers within Toledo with 15 or more employees must provide applicants who receive a conditional offer of employment with the pay scale for the position.
Rhode Island
Effective as of January 1, 2023, upon request, employers must provide applicants with the wage range for the position applied. Employers must provide employees with the wage range for their position upon (1) hire, (2) a change in position, or (3) first request.
Vermont
Effective July 1, 2025, employers with five or more employees must include a wage or salary range in listings for jobs, promotions, or transfer opportunities. Limited exceptions apply to positions paid on the basis of commissions or tips.
Washington
Effective as of July 28, 2019 (revised January 1, 2023), employers with 15 or more employees must include in job postings (1) the wage or salary range, and (2) a general description of benefits and other compensation offered for the position. Upon request, employers must provide the wage or salary range to employees who are offered a new position or promotion.
Employer Takeaways
While pay transparency obligations may seem transparent enough, the implications are anything but – pay transparency laws affect nearly every aspect of workplace relationships, from hiring, recruitment, and retention to supervision, leadership, and compensation and benefits. Additionally, several pay transparency laws include costly penalties and a private right of action for violations. Accordingly, employers should take the following steps to mitigate risk and ensure compliance:
- Determine which state and local laws apply to your organization;
- Understand your obligations under the laws;
- Review your job postings to ensure compliance with all applicable laws;
- Train appropriate personnel on requirements (e.g., hiring managers, human resources, talent acquisition professionals);
- Ensure that third-party job postings comply with pay transparency obligations; and
- Review and update pay policies to ensure compliance with federal, state, and local pay equity laws.
If you have any questions related to or need assistance complying with any pay transparency laws, please reach out to the NFC Attorney with whom you typically work or call us at 973.665.9100 or 619.292.0515.
