One Week Countdown to Pay Transparency

One week from today, on October 29, 2025, the pay disclosure requirements of Massachusetts’ new pay transparency law will take effect. This means employers with 25 or more employees in Massachusetts have one more week to complete their preparations and ensure they are ready to include pay ranges in their job postings and provide the applicable pay range to job applicants and employees when circumstances demand.

Please note that this law’s data reporting requirements already went into effect on February 1, 2025, for employers with 100 or more employees in Massachusetts that are subject to federal wage data report filing requirements. See our previous client alert for a more detailed summary of the law’s requirements. Please contact us for advice if your organization missed that deadline.

The Attorney General’s Office – which is tasked with enforcing this law – has also released guidance and FAQs to assist employers in identifying the scope of, and their obligations under, the new law. Of particular note, the Attorney General’s Office advised that employers should count all employees whose “primary place of work” is Massachusetts to determine whether they meet the 25-employee threshold (thereby triggering the law’s pay range disclosure requirements). The Attorney General’s Office defines an employee’s “primary place of work” under the pay transparency law consistent with its Massachusetts Earned Sick Time FAQs. This means that an...

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