As we have reported previously, 2024 saw a slew of states adopt new pay transparency laws. Several of those laws go into effect in 2025. They include new laws in Illinois and Minnesota (both effective January 1), Vermont (effective July 1), and Massachusetts (effective July 31).
While each of the new laws requires pay transparency in job postings, they vary in terms of what employers are required to disclose (e.g., just pay ranges, or pay ranges plus benefits) and to whom (e.g., just to job applicants in postings, or to job applicants and current employees).
Below we provide an overview of each of these new laws’ unique requirements.
| Effective January 1, 2025 |
| Illinois |
Job postings must include the wage or salary range and a general description of the benefits and other compensation (i.e., bonuses, stock options, or other incentives) that the employer reasonably expects in good faith to offer for the position.
The posted range must be based on the applicable pay scale, previously determined range for the position, actual range of others holding equivalent positions, or the budgeted amount for the position. If the starting pay rate is fixed, the employer can provide the starting wage or salary rate instead of a range.
In lieu of including the wage information in the posting, employers can provide a hyperlink to a publicly viewable web page that includes the wage or salary range and benefits information.
|
| Minnesota |
Job postings must include the wage or salary range and a general description of the benefits and other compensation the employer reasonably expects in good faith to offer for the position. |
| Effective July 1, 2025 |
| Vermont |
Job postings must include the minimum and maximum annual salary or hourly wage that the employer expects in good faith to pay for the job at the time the employer creates the advertisement.
For roles paid on commission, postings must also state that the position is paid by commission, but need not describe the commission range.
For roles paid on a tipped basis, postings must also disclose that the job is tip-eligible, but need not provide information about the tip range.
|
| Effective July 31, 2025 |
| Massachusetts |
Job postings must include the pay range for the position.
Employers must also provide pay range information for employees who are offered a promotion, or transfer, to a new position with different job responsibilities.
In addition, upon request, employers must provide the pay range to an employee for their own position, or to an applicant for the position.
|
