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Friday, November 21, 2025

What Employers Should Do Before 29 October 2025 to Prepare for Massachusetts' Pay Transparency Law - The National Law Review

Starting 29 October 2025, Massachusetts’s pay transparency law1 will require employers with 25 or more Massachusetts employees to disclose wage ranges in all job postings to job applicants and current employees upon request.

Following the law’s July 2024 passage, the Massachusetts Office of the Attorney General (AGO) released FAQs2 and held a webinar3 to clarify employers’ obligations and provide guidance. This alert summarizes the law’s key provisions, as clarified by the AGO.4

Who is a Covered Employer?

Employers with at least 25 employees whose primary place of work was in Massachusetts during the prior calendar year are subject to the law’s pay transparency requirements.

An employee’s “primary place of work” means the location where the employee performs the majority of their work. The AGO adopted this definition from the Massachusetts Earned Sick Time Law FAQs.5

How Should Employers Count Employees?

To determine whether they meet the 25-employee threshold, employers must count all individuals who performed services for wages, remuneration, or other compensation, including full-time, part-time, and seasonal workers, whose primary place of work is in Massachusetts.

This includes (1) remote or hybrid employees located in Massachusetts who work for an out-of-state employer, and (2) out-of-state remote or hybrid employees whose primary place of work is Massachusetts (e.g., they report to or are assigned a Massachusetts worksite).

Employers should calculate their headcount...



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