by In 2024, more state legislatures passed laws requiring employers to provide pay information in job postings. These laws, commonly known as pay transparency laws, typically require employers to share information relating to job compensation with applicants. The criteria for which employers are covered by the law and whether pay transparency extends to current employees differ from state to state. States being added to the list of those requiring pay transparency include Maryland, Illinois, Vermont, Massachusetts, Minnesota, and New Jersey.
Maryland: Beginning October 1, 2024, employers with job postings for positions that will be physically performed at least in part in Maryland must disclose in each internal and public posting the wage range for the position, a general description of benefits, and any other compensation offered for the position. If no public or internal job posting is issued for an available position, the employer is required to disclose to the applicants the wage range, general description of benefits, and any other compensation offered for the position prior to any discussion with the applicant about compensation and at any other time upon request of the applicant.
Illinois: The pay transparency law becomes effective on January 1, 2025. It mandates that employers with 15 or more employees disclose the wage or salary range and a general description of benefits and other compensation expected for a position. This includes bonuses, stock options, or other incentives. Additionally, employers must inform current employees about promotion opportunities no later than 14 calendar days after posting the position externally.
Vermont: Effective July 1, 2025, employers with four or more employees in the state will be required to include minimum and maximum annual salaries or hourly wages in job advertisements. The law makes an exception for job advertisements where the successful applicant will be paid on a commission basis. Covered job openings include any open position that is (1) either physically located in Vermont or a remote position where the majority of the work is done in Vermont and (2) a position for which an employer is hiring, including job postings for internal and external candidates, or promotions.
Massachusetts: Effective July 31, 2025, employers with 25 or more employees must include salary ranges in job postings. Salary ranges must be provided to current employees upon request for their existing roles and to employees who are offered a promotion or transfer to a new position with different job responsibilities.
Minnesota: Effective October 1, 2024, employers with 30 or more employees at one or more sites in Minnesota were required to post information about the state’s pay transparency law. Effective January 1, 2025, job postings by covered employers must include the salary or wage range and a general description of all benefits and other compensation, including health or retirement benefits, bonuses, or other financial benefits to be offered.
New Jersey: Starting June 1, 2025, businesses with 10 or more employees over 20 calendar weeks that do business, employ workers, or take job applications for New Jersey employment will be required to disclose certain compensation and benefits information in job listings and for promotional opportunities. Covered employers will be required to make reasonable efforts to announce or post information on certain promotional opportunities to current employees in affected departments.
Due to the inconsistency between states regarding who is covered by pay transparency laws, Human Resources teams are advised to research whether pay transparency laws exist in the states where the employer operates, advertises jobs, or has employees. State websites may have the most current information on their laws and any regulations or other employer compliance guidance. Decisions will need to be made on how the employer will comply with compensation disclosure in the states where it is required.
