Colorado passed the Equal Pay for Equal Work Act (EPEWA) in 2019, with enforcement beginning January 1, 2021. It was the first law in the United States to require salary information in job postings — and it set the template for every state law that followed.
Two years of full enforcement have generated a meaningful body of enforcement actions, CDLE guidance, and employer learnings. Here's what's changed, what continues to trip up employers, and what the Colorado experience tells us about where national compliance is heading.
What EPEWA requires — the full picture
Colorado's law is significantly more demanding than most other states. Job postings must include:
- The hourly rate or salary compensation (or a range thereof) being offered
- A general description of bonuses, commissions, or other forms of compensation offered for the role
- A general description of benefits including health care, retirement, paid time off, and any other benefits offered
- The expected start date, if known at the time of posting
The benefits disclosure requirement is what separates Colorado from every other US state. While California and New York require only a salary range, Colorado expects meaningful benefits disclosure. That means specific information — not placeholders. The Colorado Department of Labor and Employment (CDLE) has been explicit about this in its enforcement guidance.
Two years of enforcement: what the data shows
The CDLE has been actively investigating complaints since 2021, and the pattern of violations is instructive:
- Missing salary range entirely remains the most common violation, even now. Companies that haven't centralised their posting workflow often have individual hiring managers or recruiters skipping the requirement.
- Benefits descriptions that are too vague — "competitive benefits" or "comprehensive package" — are consistently flagged. The CDLE has repeatedly stated these descriptions fail to satisfy the law.
- Remote roles are a persistent grey area. Colorado's position is clear: if a Colorado resident can apply, the law applies. Employers who post remote roles with no geographic restriction cannot exclude Colorado from the law's reach.
- Outdated salary ranges are an emerging issue. Employers who posted ranges in early 2023 and haven't updated them may find that their documented good-faith range no longer reflects current compensation, particularly in fast-moving salary markets.
The "not open to Colorado residents" backlash
When the law first came into force, a notable number of national employers took the approach of simply excluding Colorado residents from remote role postings. Job ads appeared on major platforms with explicit language stating the role was not available to Colorado applicants.
The CDLE moved quickly to signal that this approach violated the spirit and potentially the letter of the law. While the original legislation didn't explicitly prohibit geographic exclusions, the CDLE's 2021 guidance made clear that employers using location exclusions specifically to avoid compliance would face scrutiny. Most employers abandoned the tactic within months. Today, it's a non-starter — both legally and reputationally.
What constitutes a compliant benefits description?
This is where most employers still struggle. The CDLE requires benefits disclosure to be "specific and meaningful." Acceptable examples include:
- "Medical, dental, and vision insurance; 401(k) with 4% employer match; 20 days PTO plus federal holidays; $1,500 annual professional development budget; equity participation"
- "Comprehensive health benefits including medical, dental and vision; flexible PTO; 401(k) with employer match; stock options; remote-first work environment"
Unacceptable formulations include "competitive benefits package," "comprehensive benefits," "industry-leading benefits," or any similar vague description. If you wouldn't feel comfortable defending the description in a CDLE investigation, it's not specific enough.
Colorado hiring?
Role Canary checks every posting for EPEWA compliance — salary range, benefits, and bonuses.
What the Colorado experience predicts about the future
Colorado's law has been a proving ground for pay transparency enforcement nationally. Several patterns from Colorado are now repeating in other states:
- States are copying Colorado's benefits disclosure model — Washington's law also requires benefits description, and more states are likely to follow
- Remote role enforcement is becoming more aggressive everywhere — Colorado's position has been adopted in spirit by NYC and California
- The good-faith standard is tightening — ranges that were considered acceptable in 2021 are being scrutinised more carefully in 2026
The clearest strategic lesson from Colorado: build your posting template to satisfy the most demanding state law, and use it everywhere. See our multi-state best practices guide for how to do this efficiently. For the national picture, see our State Law Roundup.