With the turn of the new year, employers must focus on refining their recruiting and retention efforts to ensure compliance with a handful of new pay transparency laws, specifically in Illinois, Minnesota, Vermont, Massachusetts, and New Jersey. The Illinois and Minnesota requirements became effective on January 1, 2025. The Vermont, Massachusetts, and New Jersey laws take effect at different points later in 2025.
These laws generate a host of questions, including with regard to application to staffing agencies, the use of pay bands to meet range requirements, items included in “other compensation,” the risks of going above the stated range, the size of permitted ranges, and potential applicability to remote and hybrid positions. In this article, in order of effective date, we review the primary requirements of the new laws and offer takeaways.
Quick Hits
- Illinois, Minnesota, Vermont, Massachusetts, and New Jersey have pay transparency requirements becoming effective in 2025.
- Several of the states impose requirements related to internal employees and promotional opportunities.
- Many of the requirements are currently unclear and await further guidance.
Illinois
Beginning January 1, 2025, employers with fifteen or more employees are required to include a pay scale and benefits in job postings. In addition, within fourteen days after making an external job posting for a position, employers must announce, post, publish, or otherwise make known all opportunities for promotion...
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