Effective Oct. 29, 2025, the Massachusetts law governing pay transparency, An Act Relative to Salary Range Transparency, will require covered employers in Massachusetts to disclose pay ranges in job postings.
Pay Range Requirements
The Act imposes three requirements on covered employers:
| 1. | Disclose the pay range for a position in any job posting; | |
| 2. | Disclose to a current employee, upon request, the pay range for their current position; and | |
| 3. | Disclose to a current employee the pay range for a new position when offered a promotion or transfer to such position. |
Covered Employers
Any employer, public or private, that employs 25 or more employees in Massachusetts, is a covered employer. The Office of the Massachusetts Attorney General, which is responsible for enforcing the Act, has published guidance (AG Guidance) regarding various compliance questions. With respect to out-of-state employers, the AG Guidance provides that an employee’s primary place of work is the location where the employee does most of their work for the employer. This is consistent with the definition the attorney general utilizes in interpreting the Massachusetts Earned Sick Time Law.
Employees
An “employee,” as defined by the Act, is “[a]ny person who performs services for an employer for wage, remuneration, or other compensation.” This includes all full-time, part-time, seasonal, and temporary employees.
Calculating Headcount
The AG Guidance states that employers should calculate their...
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