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Pay Equity | April 23, 2025

Are You Prepared for -Pay Transparency Requirements?

Pay transparency has become a cornerstone of modern compensation strategy and non-negotiable for legal compliance and pay equity. With over 15 states (plus D.C.) enforcing pay band disclosure and more localities joining in, HR and leadership teams face mounting scrutiny. Getting proactive now avoids fines, lawsuits, and brand damage. 

State-Level Pay Transparency & Compensation Strategy Laws 

State  Effective  Requirements & Pay Bands 
California  Jan 1 2023  Under SB 1162 (Cal. Labor Code § 432.3; bill text), employers with 15+ employees must include pay band ranges in job postings; current employees can request pay scales. Employers with 100+ employees or labor-contractor arrangements must submit annual pay-data reports to the California Civil Rights Department. 
Colorado  Jan 1 2021  SB 19‑085: the Equal Pay for Equal Work Act mandates inclusion of salary bands and benefits in postings, internal promotion notices, and prohibits salary-history inquiries. 
Connecticut  Oct 1 2021  Requires pay band disclosure before offers or upon request. 
Maryland  Oct 1 2024  Employers must disclose pay bands on request; salary-history inquiries banned. 
Nevada  Oct 1 2021  Salary bands disclosed after the first interview; pay history ban applies. 
New York  Sept 17 2023  Statewide requirement for salary-band disclosure in all postings; remote roles reporting to NY offices included. 
Rhode Island  Jan 1 2023  Pay band disclosures required prior to compensation discussion and/or on request. 
Washington  Jan 1 2023 (amended July 2025)  Employers with 15+ employees must include pay bands and benefits descriptions in postings; non-compliance allows 5-day correction period before fines or lawsuits. 
Illinois  Jan 1 2025  Companies with 15+ employees must post good-faith salary bands and benefits details; extensive record-keeping required. 
Minnesota  Jan 1 2025  Mandatory pay bands and benefits in postings for employers with 30+ employees; open-ended bands prohibited. 
New Jersey  June 1 2025  Requires salary bands and benefits in internal/external and promotion postings for employers with 10+ employees; must notify current employees of internal opportunities. 
Vermont  July 1 2025  Written job ads must include wage or salary bands—including commission/tipped roles. 
Massachusetts  Oct 29 2025  Employers with 25+ employees must publish salary bands in job postings; large employers also face pay-data reporting requirements. 

Local (City/County) Pay Transparency Ordinances 

  • Washington, D.C. (June 2024): Mandates pay bands, benefits and prohibits pay-history questions. 
  • New York City (Nov 2022): Requires explicit salary bands in postings (4+ employees); violations result in fines and damage claims. 
  • Westchester County, NY (Nov 2022): Salary bands required; pay-history ban; violations up to $125K. 
  • Ithaca, NY (Sept 2022): Employers with 4+ employees must include pay bands in job, promotion, and transfer ads. 
  • Jersey City, NJ (2022): Employers with 5+ employees must list salary bands and benefits; pay-history restrictions apply. 
  • Cincinnati, OH (Mar 2020): Post-offer salary-band disclosure required upon candidate request for employers with 15+ employees. 
  • Cleveland, OH (Oct 2025): Private employers with 15+ will need to disclose pay bands in job ads. 

Common Compliance Themes & Implications 

Salary histories are increasingly off-limits. Most of the jurisdictions listed (Colorado, Maryland, Nevada, Washington, D.C., and beyond) explicitly prohibit questions about a candidate’s past compensation. This is more than a checkbox exercise: it’s a shift toward equity-first hiring, where organizations build pay band frameworks based on the role and market, not past earnings. 

Another key trend is the requirement to proactively inform current employees of promotion or transfer opportunities. States like Colorado, Illinois, and New Jersey now require internal posting notifications, reinforcing transparency not just externally, but within the organization itself. 

The law is also catching up to benefits — no longer just a nicety, they’re part of compliance. Jurisdictions including Colorado, New Jersey, and Minnesota require employers to include a summary of benefits alongside salary bands in job postings. This offers candidates a more holistic view of total compensation. 

Record-keeping policies are tightening. Illinois mandates retention of pay-data records for up to five years, while Washington gives employers a five-day window to correct listing errors before fines or legal action. These rules aim to hold companies accountable—not just for sharing ranges, but for doing so consistently and accurately. 

On a broader scale, these transparency laws aren’t just regulatory hurdles – they’re tools for advancing pay equity. By mandating open salary bands and benefits disclosure, the policies promote fairness and accountability. For employers, adopting transparent practices signals that equity and trust are foundational to their culture—a strategic advantage in talent acquisition and retention. 

What HR & Compensation Teams Should Do Now 

Start by mapping your compliance footprint across all hiring locations, with special attention to remote roles. Whether you’re recruiting in New York City or a remote employee in Minnesota, understanding local laws ensures you publish accurate salary bands and benefits. 

Next, audit every recruitment asset—job ads (both external and internal), promotion notices, and transfer postings—to confirm they include clear pay bands and benefits statements. These essentials are now required in most jurisdictions. 

To ensure your salary bands are market-competitive and defensible, lean on salary benchmarking tools like LaborIQ. Align each pay band with current labor market data rather than outdated internal pay history. 

If you operate in states like New Jersey or Colorado, activate internal posting workflows. Automate notifications to existing staff—complete with pay band information—so you meet regulatory obligations and foster a culture of opportunity. 

Establish a strong record-retention system that complies with varying legal requirements: Illinois demands five-year retention, California three years post-employment, and Colorado two years. These archives should align with your document management and compliance systems. 

Elevate your recruitment process with targeted training. Teach hiring managers and recruiters how to clearly discuss pay bands and steer clear of banned salary-history questions, thus reinforcing transparency and compliance from first contact. 

Finally, stay alert to upcoming legislation. Vermont’s law takes effect July 1, 2025; Massachusetts follows October 29, 2025; and Cleveland rolls out in late October 2025. Build a legislative-monitoring routine—using data sources like LaborIQ and tools like SHRM and GovDocs—to adapt your systems and messaging in real time. 

LaborIQ Use Cases: Tools for HR Decision-Making 

LaborIQ empowers organizations to modernize their compensation practices and streamline compliance across several core dimensions: 

  • Pay Equity Analysis: Identify and address gender and racial pay disparities proactively, aligning with emerging equity mandates before they become legal issues. 
  • Compliance Records & Audit Trails: Maintain a comprehensive history of pay band publications and adjustments, supporting internal audits and statutory retention rules. 
  • Remote Pay Localization: For teams spread across jurisdictions like California, Washington, and Colorado, LaborIQ ensures your pay bands stay regionally aligned and legally sound. 
  • Internal Posting Alerts: Automate the publishing of internal job postings with pay bands, meeting internal notification laws and enhancing internal transparency. 

Final Takeaway 

Optimize your compensation strategy by: 

  • Publishing salary bands with benefits in every job ad, 
  • Benchmarking bands using LaborIQ, 
  • Auditing your hiring systems and record retention, 
  • Training teams to enforce pay-equity best practices. 

LaborIQ empowers HR decision-making, helping you build competitive, compliant, and equitable pay frameworks that scale. Want help building pay bands or launching internal posting policies? Our Pay Band Manager and salary benchmarking resources are ready for you. 

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