The New Jersey Department of Labor and Workforce Development (NJDOL) issued proposed regulations under the New Jersey Pay Transparency Law on September 15, 2025, that provide some (but not complete) clarity about the law’s pay and benefit disclosure requirements.

The law, which went into effect on June 1, 2025, has two broad requirements (and several exceptions to the same): (1) an employer must disclose pay and benefits information in postings for “new jobs and transfer opportunities,” and (2) an employer must give notice of “promotional opportunities” to current employees in the affected department.

Quick Hits

• New Jersey has proposed regulations and published guidance that employers without employees in New Jersey could be covered by the state’s pay transparency requirements, and that the requirements may apply to positions based outside of New Jersey.
• The proposed regulations also provide that the spread between minimum and maximum pay ranges in job postings cannot exceed 60 percent.
• The proposed regulations also provide some definitional clarity to non-salary compensation and benefits, new jobs versus transfers, and when employers could be liable for third-party dissemination of job postings.
• The proposed rule’s comment period ends November 14, 2025.

After a comment and review period, the regulations (which may be revised based on public comments received) will go into effect, likely in late 2025 or early 2026. The NJDOL recommends on its website that employers...

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