Many new or expanded laws relating to minimum pay, compensation disclosure, leave of absence, and employer notice requirements have been adopted over the past few years. Even if your business hasn’t been affected yet, these trends are likely to continue into 2026, so it may be impacted in the future. Recently, we covered trends in the areas of minimum pay and leave of absence requirements. This week, we address compensation disclosure and employer notice requirements.
Trend #3: Many states and cities are requiring pay disclosure
Several states and local jurisdictions require private sector employers to disclose the pay range for a position to an applicant or employee.
In 2025, Delaware and the cities of Cleveland and Columbus in Ohio became the latest jurisdictions to enact such a requirement. Other jurisdictions, including California and Washington, amended their existing requirements in 2025.
These laws generally have one or more of the following requirements:
- Employers must provide the salary range upon the request of an external/internal applicant.
- Employers must provide the salary range to applicants automatically at a certain point in the hiring process (e.g., at the time a job offer is made).
- Employers must include salary range information in any job posting.
Here are some examples of laws that require such disclosures.
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State or district & covered employers
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Pay disclosure requirements
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California
All employers
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Upon request, an employer must:
- Provide an applicant with the pay scale for the position for which they applied (even prior to initial interview); and
- Provide an employee with the pay scale for their current position.
An employer with 15 or more employees must include the pay scale for a position in any job posting. If the employer engages a third party to announce, post, or publish a job posting, the employer must provide the pay scale to the third party. The third party is required to include the pay scale in the job posting.
Effective January 1, 2026, the definition of “pay scale” is amended to mean a good faith estimate of the salary or hourly wage range that the employer reasonably expects to pay for the position upon hire.
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Colorado
All employers
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In each posting for each job opening, an employer must disclose:
- The rate of compensation (or a range thereof), including salary and hourly, piece, or day-rate compensation that the employer is offering for the position.
- A general description of any bonuses, commissions or other forms of compensation offered for the position.
- A general description of all employment benefits offered for the position.
- The date the application window is expected to close.
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Connecticut
All employers
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Employers must:
- Provide a job applicant with the wage range for a position for which the applicant is applying, upon the earliest of: (1) the applicant's request, or (2) prior to or at the time the applicant is made an offer of compensation; and
- Provide an employee with the wage range for their position upon: (1) their hiring, (2) a change in the employee's position with the employer, or (3) the employee's first request for a wage range.
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Delaware
Employers with more than 25 employees
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Beginning in early fall of 2027, employers must disclose the following information within notifications for all job opportunities posted internally or externally:
- The hourly or salary compensation, or the hourly or salary compensation range.
- A general description of the benefits and other compensation applicable to the job opportunity.
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District of Columbia
All employers
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Employers must provide the minimum and maximum projected salary or hourly pay in all job listings and position descriptions advertised.
In stating the minimum and maximum salary or hourly pay for the position, employers must extend the range from the lowest to the highest salary or hourly pay that they in good faith believe at the time of the posting they would pay for the advertised job, promotion or transfer opportunity.
Before the first interview, employers must also disclose to prospective employees the existence of health care benefits available to the employee.
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Hawaii
Employers with 50 or more employees
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Employers must disclose in job listings an hourly rate or salary range that reasonably reflects the actual expected compensation for the position.
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Illinois
Employers with 15 or more employees
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Employers must include in any job posting the pay scale and benefits for the position. The requirement for job postings only applies to positions that:
- Will be physically performed, at least in part, in Illinois; or
- Will be physically performed outside of Illinois, but the employee reports to a supervisor, office, or other worksite in Illinois.
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Maryland
All employers
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In each public or internal posting for each position, employers must disclose the wage range and general description of benefits and any other compensation for the position. If a posting wasn’t made available to the applicant, the employer must disclose the required information to the applicant: (1) before a discussion of compensation is held, and (2) at any other time when requested by the applicant.
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Massachusetts
Employers with 25 or more employees
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Employers with 25 or more employees in Massachusetts must:
- Disclose the pay range for a position in any job posting or advertisement.
- Provide the pay range for the position to an employee who is offered a promotion or a transfer to a new position with different job responsibilities.
- Provide the pay range for a position to an employee holding such position or to an applicant for such position upon request.
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Minnesota
Employers with 30 or more employees
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Minnesota employers with 30 or more employees must provide a minimum and maximum annual salary range or hourly range of compensation, or a fixed pay rate, on job postings. The range must be based on an employer’s good faith estimate and cannot be open-ended. Covered employers must also provide a general description of benefits and other compensation offered, including health and retirement benefits.
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Nevada
All employers
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Employers must:
- Provide the wage or salary range or rate for a position to a person who has completed an interview for the position.
- Provide the wage or salary range or rate for a promotion or transfer to a new position to an employee who has:
- Applied for the promotion or transfer;
- Completed an interview for the position or been offered it; and
- Requested the wage or salary range or rate.
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New Jersey
Employers with 10 or more employees
Jersey City, NJ
Employers with five or more employees
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An employer with 10 or more employees over 20 calendar weeks and who conducts business, employs individuals or takes applications for employment within New Jersey (also includes job placement, referral and other employment agencies, but excludes certain temporary help firms) must disclose in each internal or external posting for a new job or transfer opportunity:
- The hourly wage or salary, or a range of the hourly wage or salary; and
- A general description of benefits and other compensation programs for which the employee would be eligible
Employers that use any print or digital media circulating within the city to provide notice of employment opportunities must disclose a minimum and maximum salary and/or hourly wage, including benefits, in the posting or advertisement.
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New York
New York City, NY
Ithaca, NY
Albany County, NY
Westchester County, NY
Employers with four or more employees
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When advertising a job, promotion, or transfer opportunity, employers must state the minimum and maximum annual salary or hourly wage for the position.
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Cincinnati, OH
Cleveland, OH
Columbus, OH
Toledo, OH
Employers with 15 or more employees
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Cincinnati, OH: Upon request, employers must provide the pay scale for a position to an applicant who has received a conditional offer of employment.
Cleveland, OH: Effective October 27, 2025, employers must include a salary range for the position in all job postings
Columbus, OH: Effective December 3, 2025, employers must include a reasonable salary range in all postings for jobs that will be performed within Columbus.
Toledo, OH: Upon request, employers must provide the pay scale for a position to an applicant who has received a conditional offer of employment.
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Rhode Island
All employers
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Employers must:
- Upon request, provide the wage range for the position for which the applicant is applying.
- Provide an employee the wage range for the employee's position at the time of hire, when the employee moves into a new position, and upon request.
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Vermont
Employers with five or more employees
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Employers must disclose in job listings an hourly rate or salary range that reasonably reflects the actual expected compensation for the position. The requirement applies to job listings and advertisements for positions that are external, or internal transfers or promotions within a current employer.
Employers must take the following actions for these job openings:
- A role paid on a commission basis (in whole or in part) must disclose that the role is commission-based. It is not required to contain the role’s compensation or range of compensation.
- A role paid on a tipped basis must disclose that the role is paid on a tip basis and include the base wage or range of base wages for the job opening.
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Washington
Employers with 15 or more employees
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In each posting for each job opening, employers must disclose the wage scale or salary range and a general description of all benefits and other compensation.
Effective July 27, 2025, the law was amended to:
- Allow an employer to provide a fixed rate in job postings when only a fixed rate is offered; and
- Provide an employer (from July 27, 2025 to July 27, 2027), who is notified in writing about a non-compliant job posting, five business days to fix the posting before facing penalties.
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Trend #4: More notice requirements apply to employers
Many states and local jurisdictions are expanding the types of notices employers must provide to employees at the time of hire, during employment, and at the time of separation.
For instance, new and amended paid sick leave and paid family and medical leave laws almost always require employers to display a notice in the workplace. Many of these laws go further and require employers to furnish a separate notice to each employee and/or include a notice in any employee handbook.
Many other new employment laws also include notice requirements. Here are four examples of notice requirements that were enacted or took effect in 2025.
California
California enacted legislation that will require employers to provide a new stand-alone written notice annually to each employee, informing them of certain rights under state and federal law. Employers must furnish the notice to existing employees on or before February 1, 2026, and annually thereafter. Employers must also provide a notice to each new employee upon hire.
Minnesota
Employers with employees in Minnesota are required to issue a notice with specified information about the state’s paid family and medical leave law to each employee no more than 30 days from the beginning date of the employee's employment, or by December 1, 2025, whichever is later. Employers must also display a poster in the workplace in English and any language spoken by five or more employees.
Oregon
Effective January 1, 2026, Oregon requires that employers provide, at the time of hire, a written explanation of earnings and deductions on itemized pay statements as outlined under state law. In addition, employers are required to review and update the required information by January 1 each year.
Rhode Island
Beginning January 1, 2026, Rhode Island employers must provide all new hires with a written notice containing all the following information.
- Rate(s) of pay (including the specific application of all additional rates)
- The basis of the pay
- Pay frequency (e.g., hourly, daily, weekly, commission, salary, etc.)
- A list of deductions that may be made from the employee’s pay
- The number of days in the employee’s pay period
- The employee’s regularly scheduled payday
- The date on which the employee will receive their first paycheck
- Allowances claimed for meals and lodging
- The employee’s employment status (e.g., full-time or part-time)
- Whether the employee is exempt from minimum wage and/or overtime
Additionally, an employer must provide the following employer information:
- Legal name and any operating names
- Physical and mailing addresses of the employer’s principal place of business
- Telephone number
- All policies on sick and vacation time, personal leave, holidays and hours
Conclusion
As 2026 progresses, watch for developments in compensation disclosure, employer notice and other requirements closely and review your workplace policies, practices, and training to help ensure compliance when changes occur.
