Colorado has established one of the most comprehensive pay transparency frameworks in the United States through its Equal Pay for Equal Work Act, which requires extensive salary disclosure in job postings, mandatory notification of all job opportunities to current employees, and detailed recordkeeping requirements. As the nation’s first comprehensive pay transparency law of its kind, Colorado’s legislation has served as a model for other states seeking to promote wage equity and workplace transparency.
Here’s what you need to know about Colorado pay transparency law requirements for 2025.
Core Law & Compliance
What Is the Colorado Pay Transparency Law? (2025 Update)
Colorado’s pay transparency framework is built around the Equal Pay for Equal Work Act (C.R.S. § 8-5-101 et seq.), which took effect January 1, 2021, with significant amendments that became effective January 1, 2024.
The law consists of two main parts: Part 1 prohibits wage discrimination between employees performing substantially similar work based on sex or sex plus another protected status, while Part 2 mandates comprehensive pay transparency in job postings and promotional opportunities.
Under Part 2, employers must disclose compensation ranges, benefits information, application deadlines, and instructions for applying in all job postings. Additionally, employers must notify all current Colorado employees of job opportunities before making selection decisions and provide post-selection notices identifying who was hired or promoted.
The law applies to all employers with at least one employee in Colorado, making it one of the broadest coverage requirements among state pay transparency laws. Recent amendments have clarified career progression requirements, temporary position exemptions, and notification obligations.
Colorado Salary Posting Requirements for Employers
Colorado requires employers to include comprehensive compensation information in all job postings for positions that could be performed in Colorado, regardless of whether the posting is internal or external.
Required disclosure information includes: the actual compensation or a good faith wage range for the position; a general description of benefits and other compensation (including bonuses, commissions, and major benefits like health insurance and retirement plans); the anticipated application deadline; and clear instructions on how to apply.
Pay ranges must span from the lowest to the highest compensation the employer actually believes it will offer for the role and cannot include open-ended phrases like “$30,000 and up” or “up to $60,000.” If compensation varies by location, the posting must reflect Colorado-specific rates.
The law covers all job opportunities, including promotions and transfers, with limited exceptions for career development, temporary positions under nine months, and confidential replacements.
When Did/Does the Colorado Pay Transparency Law Take Effect?
Colorado’s original Equal Pay for Equal Work Act took effect January 1, 2021, establishing the foundational transparency requirements for job postings and employee notifications.
Significant amendments passed in 2023 became effective January 1, 2024, adding requirements for application deadlines in job postings, post-selection notices to employees, career progression disclosures, and extended statute of limitations for wage discrimination claims.
The Colorado Department of Labor and Employment has issued detailed interpretive guidance (INFO #9A) and regulations that provide additional clarity on compliance requirements, with ongoing updates to address emerging issues.
Employer Responsibilities
Which Employers Must Comply With the Colorado Pay Transparency Law?
The Colorado Equal Pay for Equal Work Act applies to all employers, public or private, that employ at least one person in Colorado. This broad coverage makes Colorado one of the most inclusive states in terms of employer coverage.
The law covers positions that could be performed in Colorado, including remote work arrangements, regardless of where the employer is physically located. However, positions that could not be performed in Colorado (such as location-specific roles in other states) are generally exempt from posting requirements.
Special provisions apply to employers with no physical presence in Colorado and fewer than 15 remote Colorado employees, who are exempt from job opportunity notice requirements until July 1, 2029, but must still comply with compensation disclosure requirements in job postings.
Colorado Pay Transparency Thresholds by Employer Size
Colorado does not use traditional employer size thresholds for most requirements, as the law applies to any employer with at least one Colorado employee.
The only size-based distinction is for employers with no physical office in Colorado and fewer than 15 remote Colorado employees, who receive limited exemptions from internal job opportunity notifications until July 1, 2029.
This approach ensures that transparency benefits reach workers across organizations of all sizes, from small startups to large corporations, reflecting Colorado’s commitment to comprehensive coverage.
Penalties for Violating the Colorado Pay Transparency Law
Colorado enforces its pay transparency requirements through the Colorado Department of Labor and Employment, which can impose significant financial penalties for violations.
Fines range from $500 to $10,000 per violation, with each non-compliant job posting or failure to provide required notices constituting a separate violation.
As of July 2024, Colorado had received 1,634 complaints and assessed $238,000 in fines, demonstrating active enforcement of the law. Employees can file complaints anonymously, and the Division investigates both pay equity and transparency violations.
Employee Rights & Impact
What Employees Should Know About the Colorado Pay Transparency Law
Colorado employees have extensive rights under the state’s comprehensive transparency framework, including the right to receive compensation information in all job postings for positions they could potentially perform.
All current employees must be notified of job opportunities before selection decisions are made, ensuring equal access to internal career advancement opportunities. Employees also receive post-selection notices identifying who was hired or promoted and how to express interest in similar future opportunities.
Employees in positions with defined career progressions must be informed of advancement requirements and compensation for each level of progression.
Workers are protected from retaliation for discussing wages, filing complaints, or exercising their rights under the transparency law.
Employee Rights Under Colorado Salary Posting Law
Colorado’s salary posting law grants employees comprehensive rights to compensation information throughout the employment lifecycle.
Job seekers benefit from mandatory salary range disclosure in all job postings, including minimum and maximum compensation, benefits descriptions, and application instructions. This upfront transparency eliminates guesswork and enables informed decision-making.
Current employees have the right to notification of all job opportunities on the same day, ensuring fair access to internal advancement opportunities. They also receive post-selection notices identifying successful candidates and pathways for expressing interest in similar roles.
Employees in career progression tracks have the right to detailed information about advancement requirements, compensation at each level, and timelines for progression opportunities.
How the Colorado Pay Transparency Law Helps Reduce Wage Gaps
Colorado’s comprehensive approach directly addresses multiple factors that contribute to wage disparities through systematic transparency requirements.
Mandatory salary range disclosure eliminates information asymmetries that historically disadvantaged certain groups during negotiations, while preventing employers from using salary history to perpetuate past discrimination.
The requirement to notify all employees of job opportunities ensures equal access to advancement, preventing informal networks from creating unequal opportunities for career progression.
Post-selection notifications and career progression disclosures provide ongoing transparency that helps employees understand advancement pathways and identify potential disparities in promotion patterns.
HR & Legal Best Practices
How HR Teams Can Comply With Colorado Pay Transparency Law
HR teams should implement comprehensive compliance procedures covering all aspects of Colorado’s multi-layered requirements, starting with establishing standardized processes for creating compliant job postings that include all required compensation and benefits information.
Developing systems for simultaneously notifying all Colorado employees of job opportunities ensures compliance with same-day notification requirements while maintaining fairness in the process.
Creating procedures for post-selection notices within 30 days of hiring or promotion decisions helps meet the law’s notification requirements while maintaining appropriate privacy protections.
Implementing robust recordkeeping systems for job descriptions and wage histories ensures compliance with the two-year retention requirement while supporting potential audits or investigations.
Updating Job Postings to Meet Colorado Salary Transparency Rules
Job postings must be comprehensively updated to include realistic wage ranges spanning the lowest to highest compensation the employer genuinely expects to pay, specific benefits descriptions covering major offerings like health insurance and retirement plans, clear application deadlines (or statements about ongoing acceptance), and detailed application instructions.
Wage ranges must be Colorado-specific if compensation varies by location and cannot include open-ended language that lacks clear minimum or maximum amounts.
Benefits descriptions must cover major offerings but need not include minor perks like employee discounts, with language that clearly explains what benefits are provided without requiring specific dollar amounts or detailed coverage information.
Regular review and updates of posting templates help maintain consistency across roles while ensuring ongoing compliance with evolving requirements.
Does the Colorado Pay Transparency Law Apply to Remote or Hybrid Workers?
Colorado’s law applies broadly to positions that could be performed in Colorado, including remote and hybrid arrangements, regardless of where the employer is physically located.
Employers must include Colorado employees in job opportunity notifications for all positions, including those performed entirely outside Colorado, though compensation information is only required for Colorado-eligible positions.
The special exemption for employers with no Colorado office and fewer than 15 remote Colorado employees until July 1, 2029, provides some relief for certain remote work arrangements while maintaining core transparency requirements.
Employers should ensure their notification and posting procedures account for all work arrangements and provide equal access to opportunities regardless of employee location.
Comparison and Broader Context
How Colorado Pay Transparency Rules Compare With California and New York
Colorado’s approach is more comprehensive than many other states, particularly in its requirements for internal job opportunity notifications and post-selection notices that go beyond what California and New York currently require.
While California and New York focus primarily on job posting transparency, Colorado’s law extends to ongoing employee notifications and career progression disclosures, creating a more comprehensive transparency framework throughout the employment relationship.
Colorado’s universal coverage starting with one employee is broader than size-based thresholds in other states, though the penalty structure is comparable to other comprehensive transparency states.
Federal Pay Transparency Requirements vs. Colorado Law
Colorado’s requirements significantly exceed current federal pay transparency protections, providing workers with comprehensive disclosure rights and employers with detailed obligations that go far beyond federal minimums.
The state’s proactive disclosure requirements, internal notification obligations, and robust enforcement mechanisms create protections that are substantially more comprehensive than federal law provides.
Colorado’s approach demonstrates how state-level legislation can provide enhanced worker protections while serving as a model for potential federal transparency requirements.
Pay Transparency Laws by State: Where Does Colorado Stand?
Colorado stands as one of the most progressive and comprehensive states in pay transparency legislation, serving as a model that has influenced similar laws in other states.
The state’s early adoption of comprehensive requirements, including internal notification obligations and post-selection notices, places it at the forefront of the transparency movement.
Colorado’s approach has demonstrated the feasibility of extensive transparency requirements while providing a template for other states considering similar legislation.
FAQs About the Colorado Pay Transparency Law
Do small businesses need to comply with Colorado pay transparency law?
Yes, all employers with at least one employee in Colorado must comply with the pay transparency requirements, regardless of business size. This includes salary range disclosure in job postings, benefits descriptions, and application information. Small businesses must also notify Colorado employees of job opportunities, though there are limited exemptions for very small remote employers with no Colorado office and fewer than 15 Colorado-based employees.
How should employers update existing job postings?
Employers should immediately update all job postings to include specific wage ranges (with clear minimum and maximum amounts), general descriptions of major benefits and other compensation, application deadlines or statements about ongoing acceptance, and clear instructions for applying. Wage ranges must reflect what the employer genuinely expects to pay in Colorado and cannot use open-ended language.
Are salary ranges required for internal postings as well as external ones?
Yes, Colorado requires the same comprehensive compensation information for internal job opportunity notices as for external postings. All Colorado employees must be notified of job opportunities on the same day before selection decisions, and postings for Colorado-eligible positions must include salary ranges, benefits information, and application details. Limited exceptions apply for career development and temporary positions.
What happens if employers fail to disclose salaries?
Employers who violate Colorado’s pay transparency requirements face fines ranging from $500 to $10,000 per violation, with each non-compliant posting or missing notification constituting a separate violation. The Colorado Department of Labor and Employment actively investigates complaints and has assessed significant fines since the law’s implementation. Employees can file complaints anonymously, and violations can result in both financial penalties and required corrective actions.
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