Pay Transparency Laws are being adopted in more states across the county with several going into effect in the coming weeks. New Jersey has a law that will be effective starting June 1, 2025, followed by Vermont becoming effective July 1, 2025, and Massachusetts on October 29, 2025. Further, on May 20, 2025, a bill was signed into law that amends the Washington State Equal Pay and Opportunities Act, which will begin July 27, 2025. As pay transparency laws are adopted and amended, multi-state employers must prepare for a patchwork of requirements by implementing consistent, scalable pay transparency practices.

New Jersey Employers

Starting June 1, 2025, employers with 10 or more employees doing business in New Jersey will be required to meet specific requirements for all job postings. This applies to both internal and external advertised postings for new jobs and transfer opportunities.

Requirements for Employers Hiring in New Jersey

  • Employers must post a range for the hourly wage or salary for a position.
  • The post must include a general description of benefits and other compensation programs for which the position would be eligible.
  • The employer must announce, post, or otherwise make known opportunities for promotion to all current employees in the affected departments prior to making a promotion decision.

The law does not specify any recordkeeping requirements, but as a best practice employers should keep records of job descriptions and wage history for each job, promotion or transfer opportunity in New Jersey. Employers with employees in New Jersey may want to review their job listings for internal promotions to ensure compliance. Noncompliance with the new requirements may lead to civil penalties of up to $300 for the first violation and $600 for subsequent violations.

Washington State Employers

Employers that have 15 employees or more need to know the following key provisions in the recently amended law that will go into effect on July 27, 2025:

  • Fixed Pay Disclosure: Employers may list a fixed wage instead of a range if only one amount is offered, including for internal transfers. This is a change from the strict policy that a pay range was required.
  • Definition of “Posting”: The amendment makes clear that job postings do not include listings that are digitally replicated and published without an employer’s consent.
    • Employers are not liable for unauthorized third-party postings but must issue correction demands and retain proof of such demand.
  • Correction Window (2025–2027): For two years between the law’s effective date and until July 27, 2027, employers have five business days to correct noncompliant postings after receiving a written notice from the state. If the posting is corrected in time, no penalties will apply.

The law does not specify any recordkeeping requirements, but as a best practice employers should keep records of job descriptions and wage history for each job, promotion or transfer opportunity in New Jersey. Employers with employees in New Jersey may want to review their job listings for internal promotions to ensure compliance. Noncompliance with the new requirements may lead to civil penalties of up to $300 for the first violation and $600 for subsequent violations.

Massachusetts Employers

Starting October 29, 2025, employers with 25 or more employees working at or reporting to a location in Massachusetts will be required to meet specific requirements for any ad or job posting intended to recruit applicants, including those published by a third-party.

Requirements for Employers Hiring in Massachusetts

Covered employers must include a pay range in all job postings. The law applies to internal and external postings and must be provided to employees who are offered promotions or transfers to new positions with different job responsibilities.

Pay range means the annual salary range or hourly range for the position, and it must be provided in good faith, meaning it should be a reasonable estimation of what the open position will actually pay.

The law also requires that covered employers provide the pay range for a position to an employee currently holding that position, upon their request. This means that employers need to be prepared to answer the question, “What is the pay range for my position?” for any employee, and ideally, the range they provide should be both defensible and fair.

Penalties

A covered employer found to have violated this requirement is subject to the following penalties:

  • Warning for the first offense.
  • A fine of not more than $500 for the second offense.
  • A fine of not more than $1,000 for the third offense; and
  • A fourth or subsequent offense shall be subject to a fine of no more than $50,000 or imprisonment for not more than two years, or by both such fine and such imprisonment.

Until October 29, 2027, covered employers will have 2 business days to cure defects upon receipt of a Notice to Cure letter from the Attorney General’s Office.

Next Steps

Multi-state employers should evaluate their pay transparency practices and begin implementing consistent and scalable pay transparency practices that meet or exceed the patchwork of requirements across all states. Employer best practices include having a formalized and documented compensation structure in place, which includes pay ranges for each position.

Additional Resources

Connect with a Sequoia consultant to learn how Sequoia’s compliance services are integrated in our benefits services and tailored solutions.  And if you’re already a Sequoia client, stay on top of your employer obligations with your Compliance Checklist that highlights important compliance dates, action items, and resources. 

The information and materials on this blog are provided for informational purposes only and are not intended to constitute legal or tax advice. Information provided in this blog may not reflect the most current legal developments and may vary by jurisdiction. The content on this blog is for general informational purposes only and does not apply to any particular facts or circumstances. The use of this blog does not in any way establish an attorney-client relationship, nor should any such relationship be implied, and the contents do not constitute legal or tax advice. If you require legal or tax advice, please consult with a licensed attorney or tax professional in your jurisdiction. The contributing authors expressly disclaim all liability to any persons or entities with respect to any action or inaction based on the contents of this blog. © 2025 Sequoia Consulting Group. All Rights Reserved. 

Séamus McGuire — Séamus is a Compliance Specialist for Sequoia, where he works with our clients to optimize and streamline benefits compliance. In his free time, Séamus enjoys riding rollercoasters, attending Broadway shows and traveling with his husband.