Pay transparency used to be a conversation about company culture. Now it is increasingly a legal requirement, and the map of states and cities with active salary disclosure laws is growing every year. Businesses operating in multiple states or expanding hiring need to get ahead of this rather than react to it.

What Pay Transparency Actually Means

Pay transparency laws generally fall into a few categories. Some require employers to include salary ranges in job postings. Some require providing pay range information to current employees upon request. Some require disclosing ranges when promoting employees or moving them into new roles. Some do all of the above.

The specifics vary significantly by jurisdiction, which is what makes this complicated for multi-state employers. Requirements in Colorado are different from what is required in New York City, Illinois, or Washington.

States With Active Requirements

Colorado was one of the first states to require salary ranges in job postings and has been enforcing its Equal Pay for Equal Work Act since 2021. The law covers any employer with at least one Colorado employee, which caught a lot of out-of-state companies off guard when they were posting remote roles.

California requires employers with 15 or more employees to include pay scales in job postings. It also requires employers to provide pay scale information to current employees upon request and submit pay data reports to the state.

New York State and New York City each have their own requirements. New York City’s law, covering employers with four or more workers, requires salary ranges in job postings. The state law extended similar requirements more broadly.

Washington, Illinois, and Massachusetts have all passed their own versions. Massachusetts’ law took effect in October 2025 for employers with 25 or more employees. This list will keep growing, and the specifics of each law continue to evolve. Verifying the current rules for each state where employees are located or hired is essential before publishing job postings.

Note: State pay transparency laws update frequently. Always verify current requirements for each state with legal counsel or a compliance resource before publishing job postings.

What Counts as a Compliant Pay Range

One mistake employers make early on is posting ranges so wide they are essentially meaningless. A range of $40,000 to $120,000 for a single role does not provide the good-faith salary information these laws are designed to require. Several state agencies have indicated they expect ranges to reflect what the employer expects to pay for the role.

Another common issue is forgetting to update postings when salary bands change. Refreshing a job posting without updating the pay range can leave an employer technically out of compliance even if the original posting was fine.

What This Means for Internal Pay Structure

Pay transparency laws do not just create compliance requirements for job postings. They tend to expose gaps and inconsistencies in how compensation has been managed internally. When employees can see what ranges exist for roles, they ask questions about where they fall and why.

That is not a bad thing if there is a clear, defensible pay philosophy behind it. It becomes uncomfortable when compensation has been managed inconsistently or without documented criteria. Employers who have built pay bands tied to defined criteria are in a much better position when transparency becomes mandatory.

Remote Work Adds Complexity

The Colorado situation is worth calling out specifically. If a role is posted as remote and a Colorado resident could apply, Colorado’s pay transparency requirements may apply to that posting even without any physical presence in the state.

Some employers initially responded by excluding Colorado residents from remote job postings, which created its own problems. The more sustainable approach is building pay ranges that can be disclosed regardless of where the applicant is located.

Practical Steps to Get Ready

Audit current job postings and identify which ones need salary ranges added based on where the business operates or hires. Build or refine pay band structures so there are defensible ranges to disclose rather than scrambling to create them under pressure. Make sure managers know how to respond when employees ask about pay ranges, because silence or vague answers create distrust even when the underlying compensation is fair. And stay current on the regulatory landscape because this area is moving fast.