Guide

Remote Work and Job Ad Compliance: The Multi-State Problem

The shift to remote and hybrid work has created a compliance puzzle that did not exist five years ago. When a job can be performed from anywhere, which state's pay transparency law applies? The answer is increasingly: all of them where a candidate could realistically apply.

The fundamental question

Most active pay transparency laws address remote roles directly. Colorado applies when work is "to be performed, in whole or in part, in Colorado." NYC Local Law 32 applies to roles performable "in whole or in part" in New York City. California, Washington, Illinois, New Jersey, and Massachusetts all use comparable "could be performed remotely by a state resident" language.

"Trying to exclude residents of specific states from your remote job postings is not a compliant strategy. It likely creates new violations under anti-discrimination provisions."

Why geographic exclusions backfire

When Colorado's law first passed in 2021, employers tried posting remote roles with "Not open to Colorado residents." The Colorado CDLE quickly signalled this violated the law's spirit, and several states have since explicitly prohibited such exclusions. Beyond legal risk, it also signals a lack of transparency to exactly the candidates you want to attract.

The practical solution

Include salary ranges, benefits descriptions, and bonus information on every job posting, everywhere. This satisfies all active state laws, eliminates the need to track jurisdiction-by-jurisdiction, and improves application volume. See our multi-state salary range guide for the template approach.

Remote roles across multiple states? Role Canary checks every posting against all jurisdictions automatically.

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Auditing your exposure

  1. Identify all postings marked as remote or hybrid
  2. Determine which states each role is accessible from
  3. Cross-reference against the list of active pay transparency states
  4. Flag postings missing required disclosures for applicable jurisdictions

This is exactly what Role Canary automates daily. See also our Pay Transparency 101 guide.

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