Pay Transparency Laws by State: HR’s Latest Compliance Guide

Pay transparency is gaining even more momentum this summer, and HR leaders are on the front line. With one new law already in effect and another coming soon, the pressure is on to align pay practices, update job postings and prepare for stricter compliance enforcement.

Understanding each state’s rules and deadlines is essential. For HR leaders, this clarity turns pay transparency from a compliance obligation into a strategic opportunity. Below, we break down two important new laws coming into play this summer and what they mean for your team.

New Jersey Pay Equity Act

Effective June 1, 2025, the New Jersey Pay Equity Act applies to employers with 10 or more employees during at least 20 calendar weeks in the current or preceding calendar year, if they do business in New Jersey, employ workers in the state, or accept applications from New Jersey residents. 

Key employer obligations:

• Meet the state’s salary range posting requirements by including a good-faith range and a general description of benefits in all external and internal job postings. 
• Make reasonable efforts to notify current employees about promotional opportunities before filling positions. This means proactively communicating openings to internal candidates to promote fairness and transparency.

Penalties and enforcement:

• Fines up to $300 for the first violation and $600 for each subsequent violation, enforced by the New Jersey Department of Labor.
• The law does not create a private right of action or specific anti-retaliation protections. However, protections under other laws, such as the Conscientious Employee Protection Act, still apply.

What HR should do now:

• Review current job postings and promotion communication processes to ensure salary ranges and benefits descriptions are included.
• Establish clear internal communication protocols for promotions to comply with reasonable effort requirements.
• Monitor updates from the Department of Labor and legal counsel to stay informed on enforcement and compliance nuances.

Vermont Pay Transparency Law Act 155, H.704

Vermont’s Act 155, H.704, effective July 1, 2025, applies to employers with five or more employees if they have at least one employee working in Vermont or advertise jobs primarily based in the state. It focuses on providing pay transparency for positions performed primarily in Vermont, including remote roles.

Key employer obligations:

• Include a good-faith salary or hourly wage range in every written job advertisement.
• For commission-based roles, employers must disclose that the position is commission-based, but aren’t required to disclose the commission structure or a compensation range.
• For tipped positions, include the base wage or wage range.

Penalties and enforcement:

• Enforcement is handled by the Vermont Attorney General and local State’s Attorneys for unfair employment practices.
• There is no private right of action for employees.
• Employees are protected from retaliation for discussing wages or requesting pay information.

What HR should do now:

• Update job postings to include required pay details for all applicable roles.
• Ensure commission and tipped wage disclosures are accurate and clear.
• Coordinate with legal counsel to understand enforcement procedures and protect against retaliation claims.

These recent pay transparency laws signal that clear pay practices are becoming the new baseline across the country. To help you stay fully informed, here’s our comprehensive overview of pay transparency laws by state and locality.

What Are Pay Transparency Laws?

Generally speaking, pay transparency laws require employers to openly share information relating to job compensation with applicants – and sometimes with employees. They may require employers to disclose pay ranges for a particular position in a job posting or at some other point during the hiring process.

These laws are important because they help reduce the pay gap between men and women. They also help reduce pay inequities more broadly by preventing discrimination based on other protected categories, like age and religion.

In addition to ensuring legal compliance, wage transparency can reap other valuable benefits. Being transparent about compensation fosters trust with employees and shows them you’re committed to supporting pay equity and preventing improper wage gaps. And that’s a big win for employers in the battle to find and retain top talent.

How HR Can Comply With Pay Transparency Regulations

What can employers, especially those operating in multiple states, do to comply with evolving pay transparency legislation?

Regular check-ins on compensation packages across the company is a good best practice, according to Jamila S. Mensah, partner at Norton Rose Fulbright.

“Specifically, for multistate employers, use the broadest approach,” Mensah said. “Figure out which jurisdiction has the strictest law and consider whether it’s reasonable to apply that to your practices generally. If you’re complying with the strictest of them, that should check the boxes everywhere and simplify your processes for compliance, from an administrative perspective.”

Which States Have Pay Transparency Laws?

Regularly review this list to ensure your policies stay compliant as pay transparency laws evolve.

California Amendment: Provide Pay Scale Info Upon Request

In 2022, Gov. Gavin Newsom signed a new California pay transparency law that expanded already existing state-law transparency requirements. It took effect in early 2023.

Prior to the new law, California employers had to provide pay scale information upon receipt of an applicant’s request if the applicant had completed an initial interview.

Under the new 2023 law, employers with at least 15 employees must disclose a position’s pay scale in all job postings. In addition, they must provide pay scale information for a position to any applicant “upon reasonable request.” It also requires employers to provide salary ranges to current employees upon request.

Employers covered by the law cannot rely on an applicant’s salary history to determine whether to hire an applicant and what to pay them. Nor can they seek information about an applicant’s salary history at the time of hire or any other time leading up to employment.

They can still ask applicants what they would like to be paid, and they are also in the clear if an applicant voluntarily discloses their salary history or if their salary history is disclosable to the public under an applicable federal or state law.

Penalties range from $100 to $10,000 per violation.

Colorado Employers Must Provide Notice for Job Opportunities

The state’s Equal Pay for Equal Work Act took effect in 2021. The law requires employers to include information about job compensation in job postings and tell their current employees about opportunities for promotions.

Colorado’s pay transparency law was amended to impose new requirements on employers beginning at the start of 2024. The amendments require employers to provide notice internally for all job opportunities and not just those relating to promotions. They also set new post-selection notification requirements. More specifically, employers must provide information about the newly selected candidates to other employees with whom the new hire will regularly work.

Job postings must include the hourly or salary compensation or the range of the hourly or salary compensation; a general description of any other compensation or benefits; and the date when applications for the job will no longer be accepted.

The law covers public and private employers that employ at least one person in the state.

Violations may result in fines ranging from $500 to $10,000 per violation.

Connecticut Pay Transparency Law Requires Wage Ranges

The state of Connecticut’s pay transparency requirements went into effect in 2021. It applies to all employers with one or more employees.

The law also says employers must provide the wage range for the position upon an applicant’s request or before an offer is made – whichever is earlier.

Similarly, employers must tell employees the wage range for their position at the time of hire, when their position changes, or upon the employee’s request.

This state law also blocks employers from inquiring with a third party and directing a third party to find out about an applicant’s wage and salary history. There’s no problem for the employer if the applicant voluntarily discloses this information or if state or federal law authorizes the disclosure of the information.

An employer that violates this law may find itself in court, as the law specifically says violations can be redressed by court actions. Applicants or employees who sue successfully can get compensatory damages, attorneys’ fees and costs, punitive damages and other relief. They have two years to file a lawsuit.

Hawaii: What to Include in Job Postings

Hawaii’s pay transparency requirements took effect at the start of 2024.

Under the Hawaii pay transparency law, employers with at least 50 employees must include a job’s salary range or hourly rate in job postings and advertisements.

The law does not require the posting of wage ranges for job listings that involve internal transfers or promotions. Nor does it cover public employers, if pay is determined by collective bargaining.

The law does not set out specific penalties for violations. The Hawaii Civil Rights Commission accepts complaints that allege a violation of the law, and employers may face lawsuits for alleged violations.

Illinois Pay Transparency Law: 5-Year Record Retention Rule

Effective January 1, 2025, Illinois employers with 15 or more employees must include a good-faith pay scale and a general description of benefits and other compensation in all job postings.

The amended state law applies to positions that will be performed, at least in part, in Illinois, or to positions performed outside Illinois if the employee reports to a supervisor, office, or other worksite located in Illinois.

If a third party is used for recruiting or hiring, the employer must provide pay and benefits details to that party or a hyperlink to the required information.

Employers must also post or announce internal promotion opportunities within 14 days of any external posting for the same position.

Job posting records – including pay, benefits and wages – must be retained for five years.

The Illinois Department of Labor oversees enforcement. Penalties vary based on whether the job posting is still active:

• Active postings: Employers get a chance to fix a first or second violation before being fined – up to $500 for a first, $2,500 for a second, and up to $10,000 for any additional violations.
• Closed postings: $250 for a first violation, $2,500 for a second, and up to $10,000 for repeated issues.

Maryland Pay Transparency Law Prohibits Salary History Questions

Maryland’s pay transparency law took effect in two parts: initial wage history restrictions in October 2020 and expanded disclosure rules effective October 1, 2024. The law applies to all employers, regardless of size.

Employers may not ask about or seek salary history from applicants — directly or through a third party — and must provide a wage range, a general description of benefits, and any other compensation in all internal and external job postings. They also cannot retaliate against applicants for requesting this information.

If a role isn’t publicly posted, this information must be shared before compensation is discussed or upon request.

The Maryland Department of Labor has issued a model compliance form that employers can use, and records must be retained for at least three years after the role is filled or posted.

Enforcement includes a written warning for a first offense, and fines up to $300 per applicant or employee for a second offense within three years, increasing to $600 for additional violations within three years.

Massachusetts: Pay Range Disclosures Coming Fall 2025

The Massachusetts pay transparency law takes effect in two stages:

• Pay data reporting for private employers with 100 or more employees begins February 1, 2025.
• Pay range disclosure for employers with 25 or more employees begins October 29, 2025.

Employers with 25 or more employees must include a good-faith pay range (annual salary or hourly wage) in all job postings, including for promotions and transfers.

Private employers with at least 100 employees, subject to federal EEO-1 reporting, must submit their most recent EEO-1 report to the Commonwealth annually.

Employers may not retaliate against any applicant or employee for exercising their rights under the law.

The law will be enforced by the state attorney general’s office. Penalties escalate as follows: first offense is a warning, second offense up to $500, third offense up to $1,000, and fourth or subsequent offenses up to $25,000. For the first two years, employers have two business days after notice to cure violations before a fine is imposed.

Minnesota: Preparing Job Postings for New 2025 Requirements

Effective Jan. 1, 2025, Minnesota’s pay transparency law applies to employers with 30 or more employees.

Covered employers must include a starting salary range or fixed pay rate in all job postings. Ranges must reflect a good-faith estimate of what the employer plans to pay. Open-ended ranges are not allowed. If no range exists, a fixed pay rate must be listed.

Job postings must also include a general description of benefits and other compensation, including any health or retirement benefits. If a third party is used for recruiting or hiring, the required pay transparency details must be included in those job postings as well.

The law will be enforced by the Minnesota Department of Labor and Industry and the Minnesota Attorney General. It does not specify penalties for violations.

Nevada Pay Transparency Law

The Nevada pay transparency law took effect in October 2021. It applies to all employers and employment agencies, regardless of size.

Employers may not ask about or rely on an applicant’s wage or salary history when making hiring or compensation decisions.

After an interview, employers must disclose the wage or salary range or rate for the position. This requirement also applies to transfers and promotions, provided the employee has applied, completed an interview or received an offer, and requested the information.

Employers may still ask about salary expectations.

Violations can result in penalties of up to $5,000 per violation.

New Jersey Requires Good-Faith Salary Range

As noted above, the New Jersey Pay Equity Act went into effect on June 1, 2025.  It applies to employers with 10 or more employees during at least 20 calendar weeks in the current or preceding year who do business in New Jersey, employ workers in the state, or accept applications from New Jersey residents.

Employers must include a good-faith salary range and a general description of benefits and other compensation in all internal and external job postings. They are also required to make reasonable efforts to notify current employees about promotional opportunities before filling positions.

Violations carry fines of up to $300 for the first offense and up to $600 for subsequent violations, enforced by the New Jersey Department of Labor and Workforce Development. The law doesn’t provide a private right of action or specific anti-retaliation protections, though other state and federal protections still apply.

HR should review job postings and promotion communications, establish clear internal protocols and stay updated on enforcement guidance.

New York: What Triggers Enforcement Actions

New York state’s pay transparency law went into effect in September 2023.

Employers with at least four employees must meet the law’s requirements.

Under this law, covered employers must list the salary range for open positions in job postings and advertisements. If the compensation for a position is based on commission, the employer must disclose this fact.

Job postings and advertisements must also include the job description for the position if there is one. They also need to maintain records relating to compensation ranges and job descriptions.

The law applies to new hires as well as internal promotions and transfers.

The law does not apply to temporary help firms that are seeking to hire workers to perform work for other employers.

Employers that violate the law are subject to penalties of $1,000 for a first violation, $2,000 for a second violation, and $3,000 for any additional violations.

Rhode Island Pay Transparency Law Prohibits Retaliation

Rhode Island’s pay transparency law took effect at the start of 2023. Employers must provide the wage range prior to discussing compensation. This information must also be provided to employees when hired, when moving into a new position, or upon request.

The law prohibits employers from asking about or relying on an applicant’s wage history in hiring or compensation decisions. It also specifically prohibits retaliation against employees who discuss wages.

If an applicant voluntarily discloses their wage history without prompting after an offer is made, the employer may consider that disclosure when offering a higher wage, provided it does not create an unlawful pay differential based on protected classes such as gender.

The law applies regardless of employer size. Violations carry fines up to $1,000 for a first offense, $2,500 for a repeat violation within five years, and $5,000 for two or more violations within seven years.

Vermont Law Covers Commission and Tipped Roles

As noted above, Vermont’s Act 155, H.704 takes effect July 1, 2025. It applies to employers with five or more employees if at least one employee works in Vermont or if the employer advertises jobs primarily based in the state, including remote positions predominantly performed for a Vermont office.

Employers must include a good-faith salary or hourly wage range in every written job advertisement. For commission-based roles, employers must disclose that the position is commission-based but are not required to disclose the specific commission structure or compensation details. For tipped positions, employers must disclose the base wage or wage range.

Enforcement is handled by the Vermont Attorney General and local State’s Attorneys. The law does not create a private right of action but protects employees from retaliation for discussing wages or requesting pay information.

HR should update job postings to include required pay details, ensure commission and tipped wage disclosures are accurate, and coordinate with legal counsel on enforcement and retaliation protections.

Washington: Amended Law Introduces ‘Correction’ Period

Washington’s pay transparency law took effect in 2023 and was amended in 2025 to clarify employer responsibilities. It applies to employers with 15 or more employees, including those using third-party recruiters.

Every job posting must include a wage scale or salary range, or a fixed pay rate if only one rate is offered. Employers must also include a general description of benefits and other compensation.

The amended law gives employers five business days to fix non-compliant postings after receiving written notice. This “correction period” helps limit exposure to penalties.

Employers must provide the wage scale or salary range to employees offered internal transfers or promotions if requested. They aren’t liable for unauthorized third-party postings, but they must act to correct them when notified.

Violations may result in fines ranging from $100 to $5,000 per violation. Courts will take into account factors such as employer size and whether the violation was intentional. Affected individuals may file a lawsuit to recover statutory or actual damages only if the employer fails to correct the issue within five business days of receiving notice.

Other Jurisdictions With Pay Transparency Laws

In addition to states, at least one county and several cities have passed their own pay transparency laws.

D.C. Law Bans Screening Applicants on Wage History

A Washington, D.C. law passed in March 2024 expands earlier wage transparency rules. Employers must now include the projected pay range in all job listings and provide information about healthcare benefits before a candidate’s first interview. The law also:

• Bans screening applicants based on wage history
• Requires employers to post a workplace notice outlining employee rights
• Gives the Attorney General enforcement authority

This law builds on the 2014 Wage Transparency Act, which protects employees’ rights to discuss their wages or those of others. Employers cannot retaliate against workers for doing so. However, they can restrict access for employees, such as those in HR, who regularly handle pay data.

Fines start at $1,000 for a first offense, rise to $5,000 for a second, and jump to $20,000 for additional violations.

Jersey City, New Jersey: Postings Must Disclose Job Benefits

Jersey City’s pay transparency requirements are set forth by a Jersey City local ordinance that was approved in 2022.

Under the ordinance, employers with at least five employees must disclose a minimum and maximum salary or hourly range in job postings and advertisements. Employers covered by the ordinance may not screen job applicants based on their salary history or require that an applicant’s salary history satisfy any minimum or maximum.

The law also applies to transfers and promotions.

The city has also said job postings must disclose job benefits being offered.

The ordinance says violations are “punishable through state law,” and the city has said violations are punishable by fines of up to $2,000.

Ithaca, New York: Law Requires Salary Range Disclosures

Ithaca’s requirements relating to pay transparency took effect at the start of September 2022.

The Ithaca pay transparency law requires all employers with at least four employees to disclose a salary range when advertising a job, promotion or transfer.

The ordinance does not include any information relating to penalties for violations.

New York City, New York: Open-Ended Ranges Aren’t Allowed

New York City’s pay transparency requirements became effective at the start of November 2022.

The law applies to employers with at least four employees, and it requires all advertisements for a job, promotion or transfer to include a pay range. The range must include a minimum and maximum; it cannot be open-ended.

The law does not require disclosure of other forms of compensation, such as employer-provided insurance or overtime pay, in job postings.

The city has said violators “may have to pay monetary damages to affected employees, amend advertisements and postings, create or update policies, conduct training, provide notices of rights to employees or applicants, and engage in other forms of affirmative relief.”

It has also said civil penalties of up to $250,000 may be assessed for violations that are not corrected within 30 days following receipt of notice of a violation.

Westchester County, New York: Steep Civil Penalties

Westchester County’s pay transparency law took effect in November 2022.

The law applies to all employers in the county, except for the county itself.

Job postings for any job, promotion or transfer must disclose the pay range of the salary or hourly rate for the position.

The law does not require disclosure of other types of compensation, such as stock options, commissions or overtime pay, in job postings.

Employers may not rely on an applicant’s wage history to determine wages unless the applicant discloses that information voluntarily in support of a request for a better offer.

Nor can they require applicants to disclose their current or former wages. They are also barred from seeking that information on their own.

Violators can be subjected to a civil penalty of up to $125,000, which may be increased to up to $250,000 in cases involving a “willful, wanton or malicious” violation.

Cincinnati, Ohio: Law Doesn’t Apply to Transfers, Promotions

This city’s pay transparency requirements took effect in March 2020.

The Cincinnati pay transparency ordinance applies to employers with at least 15 employees. Those employers may not inquire about an applicant’s salary history or screen job applicants based on their current or prior compensation or salary history.

Upon request, employers must provide the pay scale for the position being sought. This requirement applies only after a conditional job offer has been made.

The law does not apply to internal transfers or promotions. Nor does it apply to applicants who have worked for the employer within the previous five years, provided the employer has the salary history relating to the applicant’s prior employment with it. The law does not apply to positions whose salaries are set by collective bargaining.

Cleveland, Ohio: New Requirements Coming Fall 2025

Cleveland’s Pay Transparency Ordinance was adopted in April 2025 and is scheduled to take effect on Oct. 27, 2025. It applies to private employers with at least 15 employees, including job placement and referral agencies, as well as the City of Cleveland itself.

Covered employers must include salary ranges in job postings. “Salary” includes wages, commissions, hourly pay and other forms of compensation. The ordinance prohibits employers from asking about, relying on or screening candidates based on salary history. Retaliation against applicants who refuse to disclose salary history is also barred. Employers may discuss salary expectations.

The ordinance does not apply to internal transfers or promotions, applicants rehired by the employer, or those who voluntarily disclose salary history. It also exempts salaries set by collective bargaining and federal, state, or local government employers, except the City of Cleveland.

Violations carry civil penalties ranging from $1,000 to $5,000. The Fair Employment and Wage Board will investigate complaints and enforce compliance.

Toledo, Ohio: Pay Scales Required After Conditional Offers

Toledo’s Pay Equity Act took effect in June 2020. It applies to employers with at least 15 employees.

Employers may not screen job applicants based on prior wages, benefits, other compensation or salary history. They are barred from relying on an applicant’s salary history when deciding whether to offer employment when determining salary or other benefits.

Upon request and once a conditional offer has been made, employers must provide a pay scale for the job.

The law does not apply to internal transfers or promotions. Nor does it apply to applicants who have worked for the employer within the previous five years, provided the employer has the salary history relating to the applicant’s prior employment with it. The law does not apply to positions whose salaries are set by collective bargaining.

Aggrieved applicants have two years from the accrual of the cause of action to pursue a private right of action under the ordinance.

Next Steps: How to Prepare for Pay Transparency in 2025

Whether you’re facing a new state law or fielding tougher questions from job candidates, pay transparency is no longer optional. Here’s where your HR team should focus now:

Clarify how you talk about pay. Make sure recruiters and managers are ready to answer questions about salary ranges during interviews. Treat the range as a starting point – not a script – and connect it to your full compensation offer, including benefits and perks.

Standardize your pay structure. Align salary ranges across departments so they reflect market realities and internal equity. If your pay data is all over the map, fix that before it becomes a compliance issue or an employer brand problem.

Sell the full package. Pay matters, but it’s not the whole story. Make sure your job postings reflect the bigger picture – career growth, flexibility, mission, culture. Those are the things that help you stand out.

Want to go deeper? Read Pay Transparency Best Practices That Build Trust and Cut Risk for what HR teams need to know – from compliance details to culture strategy. The stakes are rising. Don’t just meet the moment – lead it.