A key component of the Massachusetts Pay Transparency Act will take effect on October 29, 2025, when many employers will be required for the first time to disclose the “pay range” of jobs in Massachusetts.
Which Employers Are Covered by the Act’s Disclosure Requirements?
The Act’s disclosure requirements apply to any employer that employs 25 or more employees in Massachusetts. According to the Massachusetts Attorney General’s Office (which enforces the Act), employees who have a “primary place of work” in Massachusetts must be included in this headcount. Massachusetts is an employee’s “primary place of work” if the employee spends more time in Massachusetts than in any other single state. For instance, an employee who spends 40 percent of their time in Massachusetts, 30 percent in Rhode Island, and 30 percent in Connecticut is considered to have their primary place of work in Massachusetts. All employees, including full-time, part-time, seasonal, and temporary employees must be included in the headcount.
Employers must calculate their headcount once per year, as an average over all payroll periods of that year. According to the Attorney General’s Office, employers should do this by adding the number of employees on the payroll during each pay period of the year and dividing by the number of pay period.
The Disclosure Requirement
Starting October 29, 2025, employers will be required to disclose the “pay range” for a “particular and specific employment position” in three...
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