2025 Pay Transparency Requirements

Posted by

Kate Harry Shipham

Posted on

Jan 17, 2025

Illinois, Minnesota, New Jersey, Vermont, and Massachusetts are the latest states to join the growing number of states and municipalities nationwide where employers must disclose compensation details in job postings, including aligning internal procedures with state-specific transparency standards.

Effective as of January 1, 2025, Illinois and Minnesota join this list. New Jersey, Vermont and Massachusetts will join later this year.

HERE’S WHAT YOU NEED TO KNOW:

States and Municipalities Requiring Disclosure:

As of January 1, 2025, there are now 14 States and Municipalities that require employers to disclose the salary of a role.

The fine print in and around the disclosure laws are that these laws typically impact employers who have a certain number of employees. However, these numbers are usually small; for example, a minimum of 15 employers in both California and Illinois. It is also the case that the ranges required to be disclosed are good faith estimates and therefore can be relied upon with a good amount of certainty. Given this, many law firms and legal marketers are subject to and / or impacted by these laws.

The 14 States and Municipalities:

States

California (already in place)
Colorado
District of Columbia
Hawaii
Illinois (new: effective 1.1.2025)
Massachusetts (upcoming: effective 10.29.2025)
Minnesota (new: effective 1.1.2025)
New Jersey (upcoming: effective 6.1.2025)
New York
Vermont (upcoming: effective 7.1.2025)
Washington

Municipalities:

Ithaca, NY
Jersey City, NJ
Westchester County, NY

States and Cities Not Quite At Disclosure:

The following list applies to states and cities where the disclosure only happens if the applicant requests it. This is still quite different to the above locations where it is termed compulsory disclosure. In this instance, the applicant needs to know they can request the information, and in some cases they have to wait until they are part of the interview process to make the request.

Cincinnati, OH
Connecticut
Maryland
Nevada
Rhode Island
Toledo, OH

The Path Forward

The salary disclosure laws are becoming more commonplace, with many legal markets being affected. This is part of a growing trend where salaries are becoming more transparent across the board. KHS People is an advocate of these trends and produces its own salary surveys to further this cause.

Here is our final parting guidance given the salary disclosure laws currently in place, which will only keep growing into other cities and states:

Firms operating in these jurisdictions, or those recruiting candidates in these areas, should carefully review their job posting practices to ensure compliance with all pay and benefits disclosure obligations. Firms should also implement processes to monitor where job postings appear and develop strategies for managing remote hiring compliance.
Firms are encouraged to conduct internal pay equity audits to identify and resolve any compensation disparities. Additionally, providing training for human resources and recruiting teams is prudent, in order to ensure understanding of the relevant pay transparency laws and the firm’s approach to establishing pay ranges and communicating compensation details to employees and candidates.

Disclaimer: This article is not intended to be providing legal advice. It is a summary and guide only, written in a way to resonate with our specific audience and network. Any questions or clarifications about the transparency laws should be directed to legal counsel.