Key State Developments and Enforcement Trends for 2025
Pay equity and transparency remain at the forefront for employers in 2025, as state legislatures and courts continue to reshape compliance obligations nationwide. For organizations with multistate operations—or even a single remote job posting—the rules surrounding compensation disclosure and equity are evolving at a rapid pace.
Across the United States, new and strengthened laws are driving greater visibility into pay practices, aiming to reduce wage gaps based on gender, race, and other factors. These measures not only impose new compliance requirements on employers but also empower employees and job seekers to better understand their worth in the workplace. For HR leaders, recruiters, and counsel advising businesses, keeping up with the latest developments is essential to navigating risk, promoting fairness, and maintaining a competitive edge.
The Expanding Patchwork of Transparency Rules
By 2025, over a dozen states have enacted pay transparency laws, with new measures in Illinois, Minnesota, New Jersey, Vermont, and Massachusetts. These laws commonly require employers to disclose salary ranges and benefits in job postings, promotions, and internal transfers. Salary history bans remain widespread, restricting reliance on prior pay.
Compliance is complex: thresholds vary from 5 to 30 employees, enforcement differs by state, and remote work adds another layer of difficulty. Collectively, these laws advance pay equity but demand close monitoring and careful policy updates from employers.
Key State Developments in 2025
- Illinois:
Effective January 1, 2025, amendments to the Illinois Equal Pay Act (HB 3129) require employers with more than 15 employees to include pay ranges and a description of benefits in all job postings. The law applies to roles performed partly in Illinois or reporting to an Illinois-based supervisor, office, or worksite, including remote positions. Additionally, employers must announce internal promotion opportunities within 14 days of external postings and retain job posting and pay records for at least five years. Penalties for non-compliance range from $500 for a first offense to $10,000 for repeat violations.
- Minnesota:
Effective January 1, 2025, Minnesota’s pay transparency law under the Omnibus Labor and Industry Policy Bill requires employers with 30 or more employees to include compensation details in job postings. Covered employers must provide a good-faith salary range—or a fixed pay rate if no range exists—ensure ranges are not open-ended, include an overview of benefits and other compensation, and refrain from asking applicants about salary history.
- New Jersey:
New Jersey’s Wage Transparency Act, effective June 1, 2025, requires employers with 10 or more employees doing business in the state to disclose pay information in job postings, including both external listings and internal transfer opportunities. Employers must provide the hourly wage or salary range for the position, include a description of benefits and compensation programs, and make reasonable efforts to notify employees of promotion opportunities. Non-compliance may result in civil penalties ranging from $300 to $600 per violation.
- Vermont
Starting July 1, 2025, Vermont’s Act 155 requires employers with five or more employees—including remote roles tied to Vermont—to include salary ranges in job postings. Covered employers must provide a good-faith salary or hourly wage range in all postings, follow special provisions for commission-based and tipped positions, and refrain from retaliating against employees or applicants who exercise their rights under the law.
- Massachusetts
Starting on October 29, 2025, Massachusetts will require employers with 25 or more employees in the state to disclose pay ranges in all job postings. Covered employers must include a good-faith pay range in all job postings, including promotions and transfers, provide pay range information to applicants and current employees upon request, and taking adverse action against employees or applicants who assert their rights under the law.
Employer Action Plan
- Review and update job postings and communications to include salary ranges and required disclosures.
- Align posted pay ranges with actual practices to reduce legal risk.
- Conduct privileged pay equity audits to assess risks while protecting sensitive analyses.
- Train HR, recruiters, and managers on compliance, including salary-history bans.
- Establish clear policies for promotions, transfers, and compensation inquiries.
- Track reporting deadlines and monitor legislative changes to stay compliant.
Pay transparency is set to become a defining standard of the workplace. As laws expand and enforcement grows stronger, employers that move beyond compliance and embrace transparency as part of their culture will gain a competitive edge—building trust, attracting talent, and shaping a fairer future of work.