2025 was the most active year for job ad compliance legislation since 2021, when Colorado pioneered salary range requirements and set the template for everything that followed. By the end of 2025, more than 20 US jurisdictions had active pay transparency requirements — and the EU Pay Transparency Directive had moved from legislation into active implementation across member states.
This roundup covers what passed, what changed in existing laws, what's coming in 2026, and how to stay ahead of it all.
New state laws that took effect in 2025
Illinois (SB 3129) — effective January 1, 2025
Illinois became one of the largest states to enact salary range requirements. Employers with 15 or more employees must include pay scale and benefits in all job postings. The law covers both employees working in Illinois and remote workers who report to an Illinois location. The Illinois Department of Labor is responsible for enforcement, with fines starting at $500 per violation for a first offense.
New Jersey (S2310) — effective June 1, 2025
New Jersey requires salary range disclosure for employers with 10 or more employees. The law covers any job posting for a role that could be performed in New Jersey — including fully remote roles. Notably, New Jersey's threshold is lower than most other states, making it applicable to a broader range of mid-sized employers. Enforcement is handled by the New Jersey Department of Labor and Workforce Development.
Minnesota (SF 3514) — expanded enforcement in 2025
Minnesota's pay transparency law had a phased implementation, with expanded enforcement beginning in 2025 for employers with 30 or more employees. The law requires salary range and a general benefits description in postings. The Minnesota Department of Labor and Industry oversees enforcement.
Significant updates to existing laws in 2025
Colorado — enhanced enforcement guidance
The Colorado Department of Labor and Employment published updated enforcement guidance in early 2025 that clarified several important points. Benefits descriptions must be "specific and meaningful" — vague language like "competitive benefits" is now explicitly called out as insufficient. The CDLE also clarified that employers must update posted salary ranges when their compensation data changes materially, not just at annual review cycles.
New York City — updated good-faith guidance
The NYC DCWP published revised enforcement guidance that addressed salary range width more directly. While it stopped short of defining a maximum acceptable range width, the guidance cited examples of ranges too wide to satisfy the good-faith standard. The DCWP also expanded its proactive audit program, moving beyond complaint-based investigations to systematic audits of major job boards.
California — first pay data reporting cycle complete
California completed its first full cycle of Pay Data Reporting under SB 1162 in 2025. Employers with 100+ employees were required to submit pay data broken down by race, ethnicity, and gender. The California Civil Rights Department made aggregate data public, providing the first systemic view of pay gaps by industry and employer size. For employers who haven't yet audited their pay equity position, the public data provides a benchmark.
What's pending in state legislatures
Several states have active legislation that is expected to move in 2026:
- Massachusetts (SB 1558): Pay transparency legislation passed the Senate and is under consideration in the House. Massachusetts would become one of the largest states to enact a salary range requirement.
- Connecticut: Existing pay equity law is being updated to require salary range disclosure in job postings, moving beyond the current right-to-request framework.
- Maryland (HB 649): Amended law expanding from pay range disclosure upon request to mandatory posting disclosure. Expected implementation in 2026.
- Ohio: Active legislation under committee review; fate uncertain but employer groups are engaged.
- Texas, Florida: No current legislation, but employer lobbying groups in both states are monitoring activity in neighbouring states.
EU: Directive transposition underway
The EU Pay Transparency Directive's June 2026 transposition deadline has pushed member states into active implementation. As of early 2026:
- Netherlands: Draft transposition legislation published in late 2025, expected to be enacted ahead of the June deadline
- Germany: Revised Entgelttransparenzgesetz incorporating Directive requirements under active parliamentary consideration
- France: Updating the Index d'égalité professionnelle framework to align with Directive requirements
- Denmark, Sweden, Finland: All three Nordic countries are expected to complete transposition ahead of schedule, building on existing strong pay transparency cultures
- Poland, Italy, Spain: More significant implementation challenges; monitoring transposition progress in neighbouring countries
For the full EU picture, see our EU Pay Transparency Directive guide. For implementing multi-state ranges efficiently, see our salary range best practices post.
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What this means for your compliance approach in 2026
The trajectory is clear: within the next two years, the majority of the US working population will live in a jurisdiction with an active pay transparency law. Combined with the EU Directive, employers hiring across multiple markets will soon be operating in a world where salary disclosure is the default expectation everywhere — not a patchwork of specific requirements in specific states.
The practical implication is straightforward: the employers best positioned for this future are the ones who adopted a universal salary disclosure policy now, rather than trying to track the minimum requirement in each jurisdiction. Build your posting template to satisfy Colorado's requirements — the most demanding — and use it everywhere. See our Pay Transparency 101 guide for the fundamentals, and our Colorado Equal Pay Act analysis for what the most demanding standard actually requires.
The other key implication is monitoring. Laws change more frequently now than they did in 2020, and the pace is accelerating. A compliance position that's correct in January 2026 may be incomplete by October 2026. Automated monitoring — rather than quarterly manual reviews — is increasingly the only reliable approach for teams managing significant hiring volume.