Pay Transparency by Country
United States
| State | Current pay transparency legislation requirement | Future requirement | Who must comply? | Penalties | Effective date | Link to bill(s) | Salary history ban? |
|---|---|---|---|---|---|---|---|
Alabama | N/A | N/A | N/A | N/A | N/A | N/A | Yes |
California | The good faith salary/hourly range in all job postings. Laws also apply to third-party posters. | N/A | Employers with 15 or more employees with at least one working in California. Also applies to general remote work postings. | Between $100–$10,000 per violation | In effect | SB 1162 | Yes |
Colorado | Salary ranges and a general description of benefits must be included in all job postings. | N/A | Employers with at least one employee working in Colorado. Also applies to general remote work postings. | Between $500–$10,000 per violation | In effect | Equal Pay for Equal Work Act | Yes |
Connecticut | Salary ranges must be provided upon candidate request or at offer (whichever is sooner). | Proposed bill would require salary ranges and benefits in every job posting. | N/A | Proposal: $1,000 – $10,000 in statutory damages + punitive damages + attorney's fees | In effect: during interview process | HB 5387 | Yes |
Delaware | N/A | Future law will require employers to post salary ranges plus benefits in all job postings | Employers with 25+ employees, which includes jobs based in Delaware and remote roles from Delaware-based employers | First offense: warning; then fines between $500-$10,000 | September 26, 2027 | HB 105 | Yes |
Georgia | N/A | N/A | N/A | N/A | N/A | N/A | City agencies in Atlanta only |
Hawaii | Employers must post the hourly rate or salary range that reasonably reflects the actual expected compensation. This also applies to roles that are internal transfers or promotions. | N/A | Hawaii employers with 50 or more employees | N/A | In effect | HI SB 1057 | Yes |
Illinois | N/A | Future law will require salary ranges and a general description of benefits and other compensation to be included in job postings beginning January 1, 2025. | Employers with 15 or more employees, and the job will be performed (at least in part) in Illinois or the employee will report to a supervisor or office in Illinois. | $500 for first violation (14 days to cure violation), $2,500 for second violation (seven days to cure violation), and $10,000 for third violation (no cure period). | January 1, 2025 | HB 3129 | Yes |
Louisiana | N/A | N/A | N/A | N/A | N/A | N/A | City of New Orleans agencies only |
Maine | N/A | Proposed bill would require salary ranges in job postings and maintain records of employees pay histories during employment and for three years after termination | Employers with 10 or more employees must include salary ranges in job postings; employers with fewer than 10 employees must disclose the salary range upon candidate request. | N/A | TBD | LD 54 | Yes |
Maryland | Employers must post the minimum and maximum hourly/salary range set in good faith in all job postings (internal/external) as well as a general description of benefits and any other compensation offered. | N/A | Employers posting a job that will be performed (at least in part) in Maryland or that reports to a supervisor/job site/office in Maryland). Will likely also apply to general remote work postings. | Warning for first violation, $300/employee or applicant for second violation, and $600/employee or applicant for subsequent violations. | In effect | HB 123HB 0649 | Yes |
Massachusetts | Employers must post the salary/hourly range that the employer, in good faith, expects to pay for a role (internal/external postings), and must also provide pay range for the role to the employee holding that position | N/A | Employers with 25 or more employees in Massachusetts (not including state/local government employees) | Warning for first offense, fine not more than $500 for second offense, and penalties increase for third offense | In effect | HB 4890 | Yes |
Michigan | N/A | Proposed salary history ban | Michigan employers | N/A | TBD | SB 145 | Yes |
Minnesota | N/A | Future law will require employers to provide the minimum to maximum hourly/salary range and a general description of benefits, beginning January 1, 2025. | Employers with 30 or more employees in Minnesota | TBD | January 1, 2025 | HF 3852 | Yes |
Mississippi | N/A | N/A | N/A | N/A | N/A | N/A | City of Jackson employers only |
Missouri | N/A | N/A | N/A | N/A | N/A | N/A | Kansas City employers with six or more employees, City employees, and City of Saint Louis employees only |
Nevada | Employers must provide salary information after first interview. | N/A | Nevada employers | N/A | In effect | SB 293 | Yes |
New Jersey | Employers with 10 or more employees over 20 calendar weeks of the year who do business, employ persons, or take applications for employment within New Jersey. Will likely also apply to general remote work. | N/A | N/A | $300 for first violation, $600 for each subsequent violations | In effect | S2310 | Yes |
New York state | Employers must post the minimum to maximum annual salary/hourly range that they, in good faith, believe they will pay for roles to be performed in NY state or roles that report to a supervisor/worksite in NY state. They must include a job description (if one exists). This also applies to promotion and transfer opportunities. | N/A | Employers with four or more employees | Up to $1,000 for first violation, up to $2,000 for second violation, and up to $3,000 for third and subsequent violations | In effect | S.9427-A/A.10477 | Yes (all employers in New York) |
New York (NYC) | Salary ranges must be posted in all jobs and promotions for roles that can be performed in NYC. | N/A | Employers with four or more employees, with at least one working in NYC. Also applies to general remote work postings. | Penalties up to $250,000 by the NYCCHR and lawsuit fees/costs | In effect | NYC Ordinance | No |
New York (Ithaca) | Salary ranges must be included in job postings. | N/A | Employers with four or more employees | N/A | In effect | Ithaca Ordinance | No |
New York (Westchester County) | Salary ranges must be included in job postings. | N/A | Any employer posting a job performed in or that can be performed in Westchester | N/A | In effect | Westchester Ordinance | No |
North Carolina | N/A | N/A | N/A | N/A | N/A | N/A | State agencies only |
Ohio (Cincinnati and Toledo Only) | Salary information must be provided upon request or after conditional offer of employment is made (whichever is sooner). | N/A | Employers with 15 or more employees in Toldeo/Cincinnati | N/A | In effect | ToledoCincinnati | Cincinnati, Columbus, and Toledo employers with 15 or more employees, not including city agencies |
Ohio (Cleveland) | Employers must provide the salary range or scale in any notification, advertisement, or other job posting. | N/A | Private employers with at least 15 people within Cleveland | Cleveland's Fair Employment and Wage Board will enforce the ordinance | In effect | Ordinance No. 104-2025 | Yes |
Oregon | N/A | N/A | N/A | N/A | N/A | N/A | Yes |
Pennsylvania | N/A | Proposed bill would require employers to provide pay ranges and the factors used to determine these ranges to applicants and employees seeking internal transfers/promotions. If the pay range isn't established, employers must disclose the minimum wage or salary before posting the job or offering the transfer. Employers will also be required to provide current employees written documentation of their pay range. | Employers with 15 or more employees | N/A | 60 days after the bill is enacted | HB 560 | State agencies; Philadelphia employers; City of Pittsburgh employees; all employers in Lehigh County |
Rhode Island | Salary information must be provided upon candidate request during the interview process. | N/A | Rhode Island employers | N/A | In effect | RI Equal Pay Law | Yes |
South Carolina | N/A | N/A | N/A | N/A | N/A | N/A | City of Columbia employees and Richland County employees only |
Utah | N/A | N/A | N/A | N/A | N/A | N/A | City of Salt Lake City employees only |
Vermont | Employers are required to post the minimum and maximum hourly/salary range that the they, in good faith, believe they will pay for a role (internal/external job postings). Employers must also disclose if the role is paid partly by tips/commissions. | N/A | Any employer posting a job performed in Vermont or a remote position that will be predominantly performed in an office/worksite in Vermont. | N/A | In effect | H. 704 | Yes |
Virginia | N/A | Proposed bill would require employers to post a salary range for each role, including promotions and transfer | TBD | Employees can bring civil actions of between $1,000–$10,000, plus attorney's fees | TBD | SB 215 | Virginia state agencies only Proposed bill would apply to all Virginia employers |
Washington state | Salary range and general benefits must be included in job postings. Salary range information must also be provided to employees changing roles, if requested. | N/A | Employers with 15 or more employees, with at least one working in Washington* | Civil actions for violations, greater of actual damages or $5,000 plus interest, costs, and reasonable attorney’s fees, AND civil penalties ranging from $500–$1,000 per violation | In effect | SB 5761 | Yes |
Washington, D.C. | Employers must post the minimum to maximum salary/hourly range that they, in good faith, believe they will pay for a role (includes promotions/transfers) and they must also inform candidate of the existence of any healthcare benefits. | N/A | Employers with at least one employee working in Washington, D.C. (not including Federal/District employees). Likely also applies to general remote work. | Attorney General can investigate potential violations and employers may pay reasonable attorney’s fees and statutory penalties | In effect | B25-0194 | Yes |
*Employers who are hiring general remote work, must comply with this law if they have at least the minimum number of employees nationwide and 1 employee working in that state
European Union
| Member State | Directive transposition status | Who? | What? | When? |
|---|---|---|---|---|
Austria | No draft published | TBD | TBD | Increasingly unlikely by June 2026. |
Belgium | FWB decree in force since 1 Jan 2025 (public sector). Federal bill pending. | French Community public sector employers. Federal scope TBD. | Salary range disclosure; salary history ban; pay gap reporting. Federal: scope still being defined. | FWB: In effect. Federal: TBD but targeting June 2026. |
Bulgaria | No draft published | TBD | TBD | Increasingly unlikely by June 2026. |
Croatia | No legislation yet. MROSP's 2026 legislative plan includes Labour Act amendments to transpose the Directive. | TBD | TBD. Labour Act amendments planned. | Increasingly unlikely by June 2026. |
Cyprus | Draft published for consultation (closed 4 Dec 2025). Awaiting submission to Parliament but Parliament is currently dissolved so stalled. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation | Clean transposition on obligations. | Increasingly unlikely by June 2026. |
Czech Republic | Act 120/2025 Sb. in force 1 Jun 2025. Further draft published 27 Mar 2026. Confirmed delay until 1 Jan 2027 | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation | Ban on pay secrecy clauses already in force. Full transposition to include mandatory remuneration systems; expanded Ombudsman role; inclusion of agency workers. | Pay secrecy ban: in effect. Full provisions: 1 Jan 2027. Reporting and Right to Information: 1 Jan 2028. |
Denmark | Draft bill amending Equal Pay Act published 26 Feb 2026. Parliamentary work suspended due to elections. | Transparency requirements: All employers. Reporting requirements: 50+ phased implementation | Full transposition. New centralized oversight body (Danish Labour Market Institute for Equal Pay). Compensation right even for information-obligation breaches. | 1 Jan 2027 (confirmed delay). First reporting for 150+ employers: September 2028. |
Estonia | No draft published. Have asked for 2-year postponement but may implement candidate transparency earlier. | TBD | TBD. Digital pay gap platform under development. | TBD |
Finland | Draft published for consultation but delay in presenting to Parliament. Transposition not expected until the end of the year. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. Existing 30+ threshold retained for current pay survey requirements. | Clean transposition on obligations. Existing pay survey obligations continue alongside new requirements. | Expected to begin in 2027 |
France | First draft circulated to social partners 6 Mar 2026. Not yet publicly available. Increasingly unlikely to meet June 2026 deadline. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 50+ phased implementation. | Significant gold-plating: pay ranges in job ads; seven reporting indicators replace existing Professional Equality Index; three-tier job classification hierarchy; "non-technical skills" and "working conditions" added to equal value criteria. Multi-stage remediation with mandatory works council consultation. | Expected to begin in 2027 |
Germany | No legislation yet. Commission final report published 7 Nov 2025. No draft bill. Increasingly unlikely to meet June 2026 deadline. | TBD | TBD | Increasingly unlikely by June 2026. |
Greece | No draft published. Working group established. | TBD | TBD | Increasingly unlikely by June 2026. |
Hungary | No draft published. New Parliament so not expected yet. | TBD | TBD | Increasingly unlikely by June 2026. |
Ireland | Draft for candiate transparency published Jan 2025 but no dates for implementation. Phased implementation of rest of Directive confirmed but no dates. | TBD | TBD | Confirmed to be phased, post-June 2026. |
Italy | Draft legislative decree given preliminary approval 5 Feb 2026 (Atto 379). Final draft expected to be released soon. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 50+ phased implementation. | Salary range in job notices (stricter than Directive — gold-plating); CBA classifications recommended | Targeting 7 June 2026. |
Latvia | Draft legislation out but still working on final draft.Increasingly unlikely to meet June 2026 deadline. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Clean transposition on obligations. | Increasingly unlikely by June 2026. |
Lithuania | Government approved draft 18 Mar 2026; forwarded to Seimas. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Centralised reporting, with employers providing data monthly; Right to Information requests to be answered within 1 month. | Targeting 7 June 2026. |
Luxembourg | No draft published. | TBD | TBD | Increasingly unlikely by June 2026. |
Malta | Candidated transparency: L.N. 112 of 2025 in force since 27 Aug 2025.Remaining transposition: no draft yet | Candidate transparency: All employers. Remaining requirements: TBD | TBD | Candidate transparency: In effect (Aug 2025). Remaining requirements: Increasingly unlikely by June 2026. |
Netherlands | Draft sent to Council of State 19 Jan 2026. Raad van State opinion issued 7 Apr 2026. Decided to delay until 1 Jan 2027 | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Clean transposition on obligations. Transparency more important than privacy for reporting and Right to Information. | Expected to begin in 2027 |
Poland | Candidate transparency: Labour Code amendments in force 24 Dec 2025. Remaining requirements: Second draft published 29 April 2026. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Clean transposition on obligations. More detail than most drafts so far. Right to Information requests based on rolling 12 months, with 1 month to respond. | Candidate transparency: In effect (Dec 2025). Remaining requirements: targeting 7 Jun 2026 but with six month delay before coming into force. |
Portugal | No draft published. | TBD | TBD | Increasingly unlikely by June 2026. |
Romania | Revised draft published for consultation 30 Mar 2026. Government now dissolved so stalled. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Procedural gold-plating proposed: 30 working-day response deadline; dedicated remuneration system; ranges on job adverts | Increasingly unlikely by June 2026. |
Slovakia | Law passed on 15 April 2026. First country to fully transpose the Directive. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation. | Clean transposition with a few date changes: remuneration is calendar year so Right to Information with category averages does not begin until 2028; reporting begins in 2027 but only for 1 Aug to 31 Dec 2026. | Act comes into force on 7 June 2026. |
Slovenia | No draft published. | TBD | TBD | Increasingly unlikely by June 2026. |
Spain | No draft published. Pre-draft consultation ended on 8 May 2026. | TBD | TBD | Increasingly unlikely by June 2026. |
Sweden | Draft published in 2025. Government announced Mar 2026 that it will delay and wants to renegotiate. | Transparency requirements: All employers. Employers under 50 exempt from pay progression obligations. Reporting requirements: 100+ phased implementation.Current 'pay survey' requirements will continue alongside Directive requirements. | Clean transposition on obligations. | Delayed indefinitely |
Canada
| Province | Current pay transparency legislation requirement | Future requirement | Who must comply? | Penalties | Effective date | Salary history ban? | Pay reporting | Link to bill(s) |
|---|---|---|---|---|---|---|---|---|
Alberta | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
British Columbia | Salary or wage information must be included on all publicly advertised job postings. Employers don’t need to include bonus pay, overtime, commissions, tips, or other benefits. | N/A | Provincially regulated employers | N/A | In effect | N/A | Pay Transparency reports through the B.C. Pay Transparency Reporting Tool. Gender pay gaps will be made public. | British Columbia’s Reg. 225/2023: Pay Transparency Act Link |
Manitoba | None | None | N/A | N/A | N/A | None | N/A | N/A |
New Brunswick | None | Proposal: Bill 24 (Pay Transparency Act) was introduced March 18, 2026. If passed, it would require salary ranges in job postings, ban salary history inquiries, and create phased pay reporting for employers with 50+ employees. | Proposal would apply to all employers and employees subject to NB legislative authority, including the Crown. No size threshold for job posting and salary history provisions. | N/A | N/A | Proposal, yes | Proposal, yes | N/A |
Newfoundland and Labrador | N/A | Requires private employers to include pay or pay range in all job postings. Enforcement date TBD, waiting on proclamation by Lieutenant-Governor in Council. | All employers | Fine of not more than $25,000 for corporations. | TBD | Passed on April 1, 2023, waiting on proclamation for effective date | Yes | N/A |
Northwestern Territories | None | None | N/A | N/A | N/A | None | None | N/A |
Nova Scotia | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Nunavut | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Ontario | N/A | As of January 1, 2026, employers must include the expected compensation, or range of compensation, in publicly advertised job postings. Ranges cannot exceed $50,000. | Employers with 25+ employees, who publicly advertises a job posting with expected compensation is less than $200,000 per year. | TBD | In effect | Proposal (not in force): Ontario's Pay Transparency Act, 2018 (SO 2018, c. 5) does contain provisions for annual pay transparency reports. Section 7 would require employers with 100+ employees to prepare and submit reports on workforce composition and compensation differences by gender (and other prescribed characteristics) by May 15 each year. Employers with 250+ employees were to file first; those with 100-249 employees were to follow. | ||
Prince Edward Island | Employers must include a proposed salary or salary range in job postings | N/A | Prince Edward Island employers | Fine not less than $200 and not more than $10,000 | In effect | Yes | N/A | Act to Amend the Employment Standards Act (Bill No. 119) |
Quebec | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Saskatchewan | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
Yukon | N/A | N/A | N/A | N/A | N/A | N/A | N/A | N/A |
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