2025 was the busiest year yet for US pay transparency legislation. Four new states passed salary disclosure laws, enforcement stepped up significantly in existing jurisdictions, and the EU Pay Transparency Directive began active national transposition across member states. This roundup covers everything that changed and what's coming in 2026 and beyond.
New laws enacted in 2025
Illinois: SB 3129 — effective January 1, 2025
Illinois SB 3129 requires pay scale and benefits information in all job postings for employers with 15 or more employees. The law applies to roles that will be performed at least partly in Illinois, or that can be performed remotely by an Illinois resident. The IDOL published an updated FAQ in January 2026 clarifying that national remote postings are covered if an Illinois resident could reasonably apply.
Enforcement: $500–$10,000 per violation. The IDOL has indicated it will prioritise high-volume employers and repeat violators in its enforcement strategy. See our Illinois SB 3129 guide for details.
New Jersey: S2310 — effective June 1, 2025
New Jersey's pay transparency law has one of the lowest employee thresholds of any active US state: 10 or more employees. The NJDOL began formal enforcement in February 2026 with fines of $1,000–$5,000 per violation for first offences. Third-party agencies posting on behalf of covered employers are also subject to the law.
The February 2026 enforcement launch has already resulted in several large employers receiving Notices of Violation for postings on major job boards. The NJDOL is conducting targeted audits of NJ-tagged postings on LinkedIn and Indeed. See our New Jersey guide for full requirements and enforcement updates.
Minnesota: SF 3514 — effective January 1, 2025
Minnesota requires salary or wage range disclosure in all postings for employers with 30 or more employees. The Department of Labor and Industry took a phased enforcement approach through mid-2025, prioritising compliance assistance over penalties during the first six months. Active enforcement began in July 2025.
Vermont: H.704 — effective July 2025
Vermont has the lowest employee threshold of any active US pay transparency law: five or more employees. The requirement applies to all postings for roles that can be performed in Vermont. Vermont's Department of Labor has issued straightforward guidance: post a salary range, and it must be genuine.
Enforcement escalation in existing jurisdictions
New York City
The DCWP continued its aggressive enforcement posture in 2025. Fines from Local Law 32 violations exceeded $8 million cumulatively through early 2026. The DCWP expanded its proactive audit program — pulling job postings from LinkedIn and Indeed and cross-checking against the salary range requirement — rather than relying solely on complaints. Employers with national remote roles continue to be the most frequent enforcement targets.
California
The California Civil Rights Department (CRD) opened 140+ investigations in 2024–2025 related to pay transparency violations. The CRD has been particularly focused on employers who technically include salary ranges but post ranges so wide as to be uninformative — a "bad faith range" argument similar to the NYC DCWP's position. California also has an annual pay data reporting requirement for employers with 100+ employees; the 2025 reporting cycle showed significant underreporting of remote workers.
Colorado
The CDLE updated its enforcement guidance in January 2026 to clarify benefits disclosure requirements. "Competitive benefits" is explicitly non-compliant. Employers must now name specific benefit types (health insurance, retirement plan, PTO policy) rather than using catch-all phrases. This update affects a significant number of existing Colorado-compliant postings that used vague benefits language.
Coming in 2026 and beyond
Massachusetts: SB 1558 — effective August 1, 2026
Massachusetts is arguably the most consequential state yet to pass a pay transparency law, given its concentration of technology, finance, and biotech employers. Signed in January 2026, SB 1558 requires salary range disclosure for employers with 25+ employees and adds a salary history ban. See our Massachusetts guide for full details and a preparation timeline.
Connecticut, Maryland, Ohio — pending
Connecticut (effective July 2026), Maryland (effective April 2026), and Ohio (active legislation) are all expected to be in force by the end of 2026. Connecticut's law closely resembles New York State's. Maryland's law applies to employers with 15+ employees. Ohio's legislation has been in committee since 2024; its prospects for 2026 passage are considered good.
EU Directive — May 2026 deadline
All 27 EU member states must complete transposition of the EU Pay Transparency Directive by June 7, 2026. The four states currently active (Germany, France, Netherlands, Ireland) will be joined by the remaining 23. For US companies with European operations or remote roles accessible to EU residents, this adds significant compliance obligations. See our EU Directive guide for what's required.
The emerging pattern: from state patchwork to near-universal coverage
When Colorado passed EPEWA in 2021, it was a regulatory curiosity. By mid-2026, more than half of the US workforce will be covered by an active pay transparency law. The direction of travel is unmistakable: national employers need a universal compliance strategy, not a jurisdiction-by-jurisdiction approach.
The practical implication: build a posting template that satisfies the most demanding requirements (Colorado and Washington — salary range + benefits + bonus), deploy it to every posting regardless of location, and implement good-faith salary range practices that reflect genuine compensation intent. This approach protects against current requirements and future legislation simultaneously.
