Latest pay transparency legal updates

We are continually updating and expanding our Research module to reflect the latest federal and state law requirements and emerging best practices. See a snippet of our latest updates below.

2026 Laws in Effect and Upcoming

Washington – Effective January 1, 2026

Washington updated its pay transparency law to require employers to disclose a fixed wage amount, rather than a scale or range, if the employer is offering only a fixed wage for a position.

California – Effective January 1, 2026

On October 8, 2025, Governor Newsom signed SB 642 into law, amending the state’s existing pay transparency law. Effective January 1, 2026, the “pay scale” that must be included in job postings needs to be a “good faith estimate” of the pay range, reflecting what the employer intends to pay a new hire. Additionally, the term “wages” will also include all forms of pay–including bonuses, stock options, benefits, travel reimbursements, and allowances. Finally, employers will also need to begin maintaining job title and wage history records for at least 3 years after the employee’s employment ends.

Maine – Effective February 9, 2026

On March 4th, Maine’s Department of Labor adopted Regulation 13098 establishing the definitions of “health care employer” and “seniority system” under its equal pay law. The definition of health care employer means any employer who operates a health care facility as defined in 22 MRSA § 328. The new definition of seniority system allows health care employers to consider both years of service and relevant education and work experience for new hires, adding provisions allowing health care employers to pay different wages according to salary schedules adopted based on the county where the place of employment is located, and requires health care employers to pay all employees performing comparable work according to equal pay requirements within the same health care facility. No other provisions of the current equal pay regulations were altered.

Oregon – Effective April 1, 2026

On April 1, 2026, an Oregon court clarified that employees are also protected from retaliation simply for asking for a raise, even where there is no claim of pay inequity or class-based discrimination. Mirkovic v. Tenasys Corp., 348 Or App 70 (2026).

California – Effective May 13, 2026

On Monday, February 2, 2026, California’s Pay data Reporting Portal opened for use. Employers with 100 or more employees are required to submit annual pay data reports through this portal. Reports for covered employers are due by May 13, 2026. Check the state FAQ for help with filing questions.

The California Civil Rights Department recently published preliminary versions of pay data reporting templates for Reporting Year 2025. The 2025 preliminary templates are a simplified version of the official templates and are intended to help filers become familiar with the expected format and data fields for Reporting Year 2025. A companion FAQ document provides answers to frequently asked questions on the templates, including three newly proposed columns to collect information on employee exemption status, employment type, and weeks worked. These templates are subject to change and are intended for planning purposes only; they should not be filed with the state. As a reminder, the employer filing period is expected to run from early February until May 13, 2026.

Washington – Effective May 22, 2026

In late April, the Washington State Department of Labor & Industries (L&I) adopted new rules implementing amendments to the Equal Pay and Opportunities Act (EPOA) that were enacted in 2025, including Substitute SB 5408, which clarifies wage and salary posting requirements under EPOA. The rules help to clarify the definitions of “applicant” and “posting” and refine guidance on the disclosure of wage or salary range by an employer. An “applicant” is any person who applies to a job posting intended to recruit job applicants for a specific available position. A “posting” is defined as any solicitation intended to recruit job applicants for a specific available position, including recruitment done directly by an employer or indirectly through a third party; “posting” does not include a solicitation for recruiting job applicants that is published without an employer’s consent. Upon request of an employee offered an internal transfer to a new position or promotion, the employer must provide the wage scale, salary range, or fixed wage amount for the employee’s new position. These rules apply to employers with 15 or more employees total at the time a job opening is posted.

Illinois – Effective June 18, 2026

On July 6, 2026, the Illinois Department of Labor adopted amended rules implementing the Equal Pay Act.

The amended rules:

  • Add definitions for terms such as “benefits,” “job posting,” “pay scale and benefits,” and “promotional opportunity.”
  • Update employer recordkeeping requirements.
  • Revise the complaint and investigation process.
  • Establish procedures for enforcing the Act.
  • Create tiered civil penalties based on employer size and the number of prior violations.
  • Establish cure periods for certain pay transparency violations.
  • Remove references to the federal EEO-1 report from the Equal Pay Registration Certificate requirements.

The penalties may apply to wage underpayment, pay transparency, and other violations of the Act. The Department also repealed several prior procedural sections.

The amended rules are effective retroactively to June 18, 2026.

Virginia – Effective July 1, 2026

On April 22, 2026, the state enacted identical bills HB 636 and SB 215 when both parts of the legislature accepted the governor’s recommended amendments, establishing prohibitions on employers from seeking or relying on the wage or salary history of prospective employees and requiring employers to disclose good faith wage or salary ranges in all job postings – internal and external. In addition, employers may not retaliate against prospective or current employees for refusing to provide wage history or requesting pay range information. The Attorney General is empowered to bring civil enforcement actions, with civil penalties of up to $1,000 for first violations and up to $5,000 for subsequent violations. Legal and equitable relief is also available to employees through private causes of action within one year of a violation; however, employers can correct posting violations within 15 business days of written notice before private actions may proceed. Both laws go into effect on July 1, 2026.

Maine – Effective July 29, 2026

On April 24, 2026, Governor Mills signed HB 18 establishing pay transparency requirements for employers in Maine. Employers with 10 or more employees will be required to include pay ranges in job postings, unless compensation is based solely on commission. Employers must also provide pay range information to employees upon request and maintain records of employee positions and pay history during employment and for three years after termination. The Department of Labor is responsible for enforcement, with appropriations provided for one Labor and Safety Inspector position and related costs for enforcement. The law takes effect on July 29, 2026.

Colorado – Effective August 12, 2026

In early June, Colorado passed HB 1207 which will require private employers with 100 or more employees to provide demographic workforce data in periodic reports to the Secretary of State, beginning July 1, 2027. Each covered employer will be required to provide EEO-1 data similar to what was collected in the Federal EEO-1 reporting format as it existed on March 1, 2026, even if the federal government discontinues the federal requirement to submit EEO-1 data to the EEOC. The law takes effect on August 12, 2026.

Connecticut – Effective October 1, 2026

On May 11, 2026, Governor Lamont signed HB 5003 amending pay transparency requirements for employers in Connecticut. The Act modifies several workforce protections; among them, pay transparency requirements have been revised to include provision of benefit descriptions and inclusion of wage ranges and benefits descriptions in job postings. Previously, wage range information was required to be provided to applicants but was not explicitly required to be included in job postings and advertisements. “Benefits” are defined as health insurance benefits, retirement benefits, fringe benefits, paid leave and any compensation other than wages offered with a position. The Act also adds retaliation protections for employees and applicants related to wage and benefit information provisions. Lastly, the Act makes slight modifications to the definition of wage range, and the timing of when pay and benefits information must be provided to an applicant. The law is effective October 1, 2026.

2025 Laws in Effect

Vermont – Effective July 1, 2025

Vermont Governor Scott signed H. 704 on June 4, 2024, implementing new wage transparency requirements. Effective July 1 of next year, employers with 5 or more employees will be required to include a good faith wage range in all job postings for positions that will be (1) located in Vermont or (2) that will be performed remotely for an office or work location that is physically located in Vermont.

New Jersey – Effective June 1, 2025

On November 10, 2024, New Jersey enacted a new wage transparency law. Beginning June 1, 2025, employers with 10 or more employees must include wage ranges and a general description of benefits in job postings. Employers must also make reasonable efforts to inform existing employees of opportunities for promotion. Employers could face up to $600 per violation.

California – Effective May 14, 2025

Under California’s pay transparency laws, employers with 100 or more employees hired through labor contractors are required to submit their annual pay data reports by May 14, 2025. Review the California Civil Rights Department’s page for more information and guidance.

 

Massachusetts – Effective February 1, 2025

Last month, Massachusetts Governor Healy signed Bill H.4890, implementing new wage transparency requirements, which take effect on different dates depending on employer size. Beginning February 1, 2025, employers with 100 or more employees in Massachusetts must provide annual wage data reports to the State Secretary. Beginning October 29, 2025, employers with 25 or more employees in Massachusetts must provide wage ranges to applicants on all job postings, to employees who are offered a new position, and to both applicants and employees upon request.

Minnesota – January 1, 2025

On May 17, 2024, Minnesota Governor Walz signed legislation implementing new wage transparency requirements for Minnesota employers. Beginning January 1, 2025, employers with 30 or more employees in Minnesota must include the starting salary range and a general description of all of the benefits and other compensation an employee can expect in all job postings. Beginning October 1, 2024, covered employers will also need to begin displaying a poster displaying employee rights under these new requirements. That poster is still being developed by the Commissioner of Labor and Industry.

Illinois –  January 1, 2025

On August 11, 2023, Governor Pritzker signed a new wage transparency bill into law. Beginning January 1, 2025, employers with at least fifteen employees will need to include in their job postings the pay scale and benefits information for the position. The law will apply to jobs performed at least partly in the state as well as jobs where the employee will report to a supervisor, office, or other work site in Illinois. We will update our tools once this change takes effect.

2024 Laws in Effect

Maryland – Effective October 1, 2024

Approved on April 25, 2024, SB 525 institutes new wage transparency requirements in Maryland. Beginning October 1, 2024, employers must disclose the wage range and a general description of benefits and other compensation in all job postings for positions that will be performed, at least in part, inside the state. Maryland has released guidance to help employers understand their responsibilities under these new requirements. We have updated our tools to reflect these new requirements.

District of Columbia – Effective July 1, 2024

Included in the same legislation prohibiting wage history inquiries, D.C. passed new wage transparency requirements. Beginning June 30, employers with at least one employee in the District must include wage ranges in all job postings and disclose the existence of healthcare benefits before the first interview. Finally, employers must post a notice informing employees of their rights under the new law.

Hiring in a new state?

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Hiring Out-of-State Employees in Virginia (Updated for 2026)
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Hiring out-of-state employees in Washington (Updated for 2026)
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Hiring Out-of-State Employees in Wisconsin (Updated for 2026)
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Hiring Out-of-State Employees in Utah (Updated for 2026)
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Hiring Out-of-State Employees in Wyoming (Updated for 2026)

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