Midyear Pay Transparency Update: Job Postings Lead Employer Responsibilities
Takeaways
- Multiple states are adding new pay transparency requirements that go into effect soon.
- Employers must include pay ranges in job postings or include wage ranges and a general description of benefits in public and internal job advertisements.
- Employers should review recruiting and posting practices now, as the new laws differ in effective dates, employer coverage, disclosure requirements and compliance obligations.
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The growing patchwork of state pay transparency laws presents ongoing compliance challenges for multi-state employers. Two new pay-posting laws take effect in July; one new law expands an existing obligation starting in October.
States continue to take different routes to require employers to provide earlier, more consistent disclosure of pay information in job advertisements used to attract candidates. The first half of 2026 sharpened that trend with more states adding to the patchwork as we move through the year: Virginia and Maine are requiring pay ranges in job postings; Connecticut is requiring in job postings what it once required only on request.
Virginia
- Who: All employers
- What: Wage, salary, or wage/salary range
- When: In public and internal postings, effective July 1, 2026
- Which jobs: Jobs, promotions, transfers, and other employment opportunities (the statute does not expressly address remote positions)
- Note: Ranges must be set in good faith; in assessing good faith, the breadth of the range may be considered, among other factors
Maine
- Who: Employers with at least 10 employees
- What: Prospective range of pay
- When: In job postings, effective July 29, 2026
- Which jobs: Positions for which the employer is actively recruiting, whether posted electronically, in hard copy, or through a third party
- Note: This law has a recordkeeping obligation as well
Connecticut
- Who: All employers
- What: Wage or wage range, plus a general description of benefits
- When: In public and internal job advertisements, effective Oct. 1, 2026
- Which jobs: Positions performed in Connecticut, and positions performed outside Connecticut if the employee reports directly to a Connecticut supervisor, office, or other worksite
- Note: Connecticut’s prior law required disclosure upon request or at the offer stage; HB 5003 (signed May 11, 2026) moves that obligation into the posting itself
What This Means for Multi-State Employers
With varying effective dates, coverage thresholds, and disclosure requirements ahead, employers should proactively review their hiring and recruitment practices and have a plan in place to monitor developments and update recruiting and job-posting practices as needed to ensure compliance and mitigate legal risk.
Establishing a process to monitor and implement new pay transparency obligations now can help ensure your organization stays in compliance and reduces opportunities for legal challenges stemming from your posting practices.
Contact a Jackson Lewis attorney with any questions and for additional information on these and other pay transparency obligations.
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