Wage Transparency Laws: What Employers Need to Know Across Multiple States and Localities

What Changed

A wave of wage transparency laws has swept across the United States, requiring employers to disclose compensation information in job postings, to applicants, or to current employees upon request. These laws aim to close the gender pay gap, reduce discrimination, and promote fairer compensation practices. Below is a jurisdiction-by-jurisdiction breakdown of the key requirements.

State Laws

State | Effective Date | Key Requirement | Employer Threshold | Penalty

California | January 1, 2023 | Pay scales in job postings; salary info to current employees on request; annual pay data reporting | 15+ employees (postings); 100+ employees (reporting) | Up to $10,000 per violation (postings); up to $200 per employee (reporting)

Colorado | January 1, 2021 | Compensation, benefits, and bonuses in all job postings; promotion notifications | 1+ employees in CO | $500–$10,000 per violation

Connecticut | October 1, 2021 | Salary ranges to applicants and employees upon request or before offer | 1+ employees in CT | Compensatory and punitive damages, attorney's fees

Maryland | October 1, 2020 | Wage range upon applicant request; salary history ban | All employers | [VERIFY]

Nevada | October 1, 2021 | Salary/wage range disclosure after interview; ranges for promotions/transfers | All employers | Up to $5,000 per violation

New York | September 2023 | Min/max salary range in job postings; salary history ban | 4+ employees | [VERIFY]

Rhode Island | January 1, 2023 | Wage ranges upon request for current or prospective roles | All employers | [VERIFY]

Washington | January 1, 2023 | Compensation, benefits, and bonuses in all job postings | 15+ employees | $500 per violation; up to $1,000 or 10% of damages for repeats

City and Local Laws

Locality | Effective Date | Key Requirement | Employer Threshold

Cincinnati, OH | March 13, 2020 | Pay range upon request; salary history ban | All employers

Jersey City, NJ | April 13, 2022 | Salary range in all job postings | 4+ employees, principal place of business in Jersey City

Ithaca, NY | September 1, 2022 | Salary range for new jobs | 4+ employees

New York City, NY | November 1, 2022 | Salary range in job advertisements | 4+ employees

Toledo, OH | [VERIFY] | Pay range upon request; salary history ban | All employers

Westchester County, NY | November 6, 2022 | Min/max salary range for jobs performed in the county | 4+ employees

Note: Westchester County's law will become null and void when New York State's pay transparency law takes effect.

Who Is Affected

The applicability varies by jurisdiction, but broadly:

• Most laws apply to employers of all sizes or employers with 4 or more employees

• Remote work complicates coverage: Several laws (California, Colorado, Connecticut, Washington) apply to remote positions if the work is performed in that state or if the employer recruits employees from that state

• Job applicants and current employees both benefit from these laws

• Salary history bans are common companions to wage transparency requirements — employers in covered jurisdictions cannot ask about prior compensation

Where It Applies

This is a multi-state and multi-locality issue. Employers must comply with the wage transparency laws in every jurisdiction where they have employees or recruit employees. The chart above provides jurisdiction-specific details.

Importantly, several of these laws have remote work provisions that extend their reach:

• California: Applies to remote positions if at least one employee is located in California

• Colorado: Applies to any employer with at least one employee in Colorado

• Washington: Applies to employers that recruit Washington-based employees, even if headquartered elsewhere

When It Takes Effect

Effective dates vary by jurisdiction (see tables above). The most recent additions as of mid-2023:

• California: January 1, 2023 (job posting requirements)

• Rhode Island: January 1, 2023

• Washington: January 1, 2023

• New York State: September 2023

Why It Matters

Wage transparency is one of the most significant trends in employment law. The business impact is substantial:

• Job postings must be revised to include salary ranges in covered jurisdictions

• Compensation structures may need to be formalized — you cannot disclose a range you have not established

• Pay equity audits become more important as employees gain visibility into how their compensation compares to posted ranges

• Multi-state employers face the most complexity, as they must navigate different requirements across jurisdictions

• Non-compliance penalties range from nominal fines to significant per-violation penalties (up to $10,000 in California)

The trend is accelerating, with new states and cities regularly considering or enacting similar legislation.

The Humareso Take

This is not slowing down — it is accelerating. If you operate in multiple states, the patchwork of wage transparency requirements is already complex and it is only getting more so. The smartest approach we have seen from multi-state employers is to adopt a company-wide pay transparency standard that meets the most stringent requirements (currently California and Colorado) and apply it everywhere. It is simpler to manage, it positions you well as more states adopt similar laws, and frankly, it is good practice. If you have not formalized your compensation ranges yet, this is the push you need.

Recommended Action Steps

1. Audit your job postings across all platforms to ensure salary ranges are included where required by law.

2. Formalize compensation ranges for all positions — you cannot disclose what you have not defined.

3. Remove salary history questions from applications and interview scripts in jurisdictions with bans.

4. Train recruiters and hiring managers on which jurisdictions require disclosure and when (in posting, upon request, before offer, or after interview).

5. Conduct a pay equity audit to identify and address any disparities that could become visible under transparency requirements.

6. Contact your Humareso representative for help building a multi-state wage transparency compliance strategy.