As employers move into the second half of 2025, pay transparency continues to expand across the states. And, perhaps, enforcement is starting to keep pace with legislative activity.

Quick Hits

• Multistate employers may want to review their pay transparency compliance requirements as they move into the second half of 2025 since such laws are being actively enforced in states like New Jersey and Illinois.
• Colorado’s rigorous enforcement of pay transparency laws has resulted in significant fines for employers, highlighting the importance of including accurate compensation information and meeting all posting requirements.
• New pay transparency laws in Massachusetts, Vermont, and Cleveland, Ohio, will take effect in late 2025, mandating salary disclosures in job postings and imposing penalties for noncompliance.

New Jersey and Illinois Begin Enforcement: Key Coverage Clarifications

Notably, both the New Jersey Department of Labor and Workforce Development and the Illinois Department of Labor have begun active enforcement of their new pay transparency laws. Employers may want to note that New Jersey’s Department of Labor and Workforce Development has clarified its position on coverage: regardless of where a position is physically located, the New Jersey pay transparency law applies if the employer meets the minimum employee threshold and does business, employs persons, or takes applications for employment within New Jersey. This expansive interpretation means that multistate...

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