In 2021, employers had to grapple with a host of new pay transparency requirements across the country, which we previously outlined here. While most of these concern requirements to provide salary range information to applicants to posted jobs, several require disclosure of salary range information to current employees under certain circumstances. Employers who have addressed pay range disclosures in job postings are well-advised to also review their practices with respect to current employees to ensure compliance.

Here’s a rundown of salary range disclosure requirements currently in effect that impose requirements concerning current employees as well as those scheduled to come online in the next year.

On the books

• Colorado: Employers must make “reasonable efforts” to “announce, post, or otherwise make known” to their Colorado employees “all opportunities for promotion”—and those notifications must include the “range of the hourly or salary compensation” for the post-promotion position if the opportunity exists (or the promotion is anticipated to take place) in Colorado. Under the state labor agency’s interpretive guidance, current employees in Colorado must thus be notified of the salary range associated with any potential promotion in Colorado before the promotion—defined to include any in-line advancement—can take place.
• Connecticut: Effective October 1, 2021, Connecticut requires employers to disclose “the wage range for the employee’s position” at three separate...

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