Ahead of the May 13, 2026, filing deadline, the California Civil Rights Department has released preliminary templates and updated FAQs for the 2025 pay data reporting cycle. Although these simplified templates may still be revised, they highlight new mandatory data fields, including exemption status, employment type, and total annual weeks worked. Read more about these recently issued resources and steps employers can take to prepare.

Massachusetts employers with 100 or more employees should prepare now for the next round of state pay reporting, as the deadline is quickly approaching. This year, the reports are due by February 2, 2026, as the normal February 1 deadline falls on a weekend and is extended to the next business day.

Massachusetts’ “An Act Relative to Salary Pay Range Transparency” requires covered private employers to submit wage data reports. As we have previously discussed, employers required to file EEO-1 reports with the EEOC satisfy this requirement by submitting their EEO-1 report to the Commonwealth on an annual basis. These pay data reporting requirements are in addition to covered employers’ pay transparency obligations under the same statute. Further, certain public-sector employers have similar responsibilities under EEO-4 reporting categories, with biennial filings due to the Commonwealth in even-numbered years.

Failure to comply may lead to state enforcement action, including potential civil penalties. Employers should confirm whether they meet the coverage threshold and ensure their filings are complete and ready for submission by the deadline.

If you have questions about compliance or your reporting obligations, contact a Jackson Lewis attorney for guidance.

On December 4, 2025, the New York City Council voted to override Mayor Eric Adams’ veto, enacting new local laws that significantly expand pay transparency obligations for private employers.

Under the new law, employers with at least 200 employees must report pay data, including demographic and occupational information, on an annual basis following a multi-year implementation period. Reporting will be phased in over several years, providing employers with runway to prepare before their first submissions are due to a yet-to-be-designated city agency. This agency will also be responsible for creating a reporting system and standardized form. Employers that fail to comply may face civil penalties and be publicly listed on the agency’s website.

Additionally, an associated measure directs the agency to conduct and publish a pay equity study, based on the reported information, to evaluate disparities and trends across industries and occupations. Only aggregated findings will be published to protect individual identities.

Jackson Lewis is closely monitoring these developments and will provide updates as details emerge. For questions about New York City’s new requirements and their potential impact on your organization, please contact a Jackson Lewis attorney.

The City of Columbus, Ohio, has joined a growing list of jurisdictions adopting pay transparency laws intended to promote pay equity. On November 4, 2025, Mayor Andrew Ginther signed an ordinance that introduces new requirements for employers and restricts salary history inquiries. This ordinance closely mirrors the Cleveland pay transparency law that went into effect last month.

The ordinance applies to employers with 15 or more employees in the City of Columbus, including private employers and the city itself.

Pay Transparency Requirements

Covered employers must include a reasonable salary range or scale in all job postings. “Salary” includes, but is not limited to, wages, commissions, hourly pay, and other monetary earnings. Postings that are replicated and published without an employer’s consent are excluded.

The reasonableness of the pay range or scale is based on specific factors for the position. Such considerations may include the employer’s budget flexibility, anticipated range of applicants’ experience, potential variation in position responsibilities, growth opportunities, cost of living, and market research.

Prohibitions on Compensation History Inquiries

The ordinance retains existing restrictions on compensation history inquiries, which prohibit employers from:

  • Inquiring about a job applicant’s salary history, including current and prior wages, compensation, or benefits.
  • Screening applicants based on their salary history.
  • Relying solely on an applicant’s salary history in deciding whether to offer employment or in determining salary, benefits, or other compensation during the hiring process.
  • Retaliating against or refusing to hire an applicant for not disclosing their salary history.

Without inquiring about a job applicant’s salary history, employers may still share the position’s anticipated salary range and discuss an applicant’s compensation expectations.

Exceptions

The ordinance does not apply to an applicant’s “voluntary and unprompted” disclosure of their salary history. If an applicant’s salary history is disclosed in an employer’s attempt to verify an applicant’s non-salary related information or conduct a background check, that information cannot be solely relied upon when making compensation decisions during the hiring process.

The ordinance’s requirements and prohibitions do not apply to:

  • Actions an employer takes pursuant to any federal, state, or local law that specifically authorizes reliance on salary history to determine employee compensation.
  • Applicants or job postings for internal transfer or promotion.
  • Rehires within three years where salary history is already known.
  • Positions for which salary, benefits, and compensation are determined pursuant to procedures established by collective bargaining.

Enforcement

The City Code will be updated on December 3, 2025, but it will not be enforced until January 1, 2027. Applicants may file complaints with the Community Relations Commission, which can impose penalties outlined in the Columbus City Codes.

Employer Takeaways

While enforcement is more than a year away, early preparation could help ensure compliance when enforcement begins. Employers should review their hiring practices and job postings to align with these pay transparency requirements.

If you have questions about pay transparency in Columbus or other jurisdictions, contact a Jackson Lewis attorney to discuss your organization’s obligations.

As a reminder, starting October 29, 2025, Massachusetts employers with 25 or more employees must comply with the Commonwealth’s new pay transparency and disclosure requirements. The Act Relative to Salary Range Transparency directs covered employers to include pay ranges in all job postings and provide this information to applicants and employees upon request.

The pay range must reflect the lowest to highest pay rate the employer reasonably and in good faith expects to offer for a position. This requirement applies to any job posting tied to a Massachusetts worksite, including certain remote roles. The law prohibits retaliation against individuals who request pay range information or exercise their rights under the statute. The Massachusetts Attorney General’s Office will enforce the law and has released FAQs to guide employers.

These pay disclosure rules are in addition to workforce data reporting requirements that took effect in February of this year under the same law. Employers with at least 100 employees must periodically submit their federal EEO reports to the Secretary of the Commonwealth, as outlined in the statute.

With the deadline only weeks away, employers should prepare now if they have not already started planning for these changes. Noncompliance can trigger investigations and penalties.

If you have questions about Massachusetts’ pay transparency requirements and how they may affect your organization, contact a Jackson Lewis attorney for assistance.

Governor Newsom signed Senate Bill (SB) 642 on October 8, 2025, revising California’s Equal Pay Act. Effective January 1, 2026, the amendments refine key definitions, including “pay scale,” “sex,” and “wages,” and limit the period to obtain relief to six years.

For more details about SB 642, read the full analysis here.

On October 9, 2025, the New York City Council passed amendments to local laws that, if passed, would impose new pay equity reporting obligations on certain private employers and require the city to conduct annual pay equity studies.  These measures are designed to identify and address wage disparities based on gender, race, and ethnicity. The amendments are now pending before the mayor, who has 30 days to sign, veto, or allow the amendments to become law automatically.

If the amendments become law, private employers with at least 200 employees that file EEO-1 Component 1 reports with the EEOC will be required to submit annual pay data reports to a city agency designated by the mayor. The data will align with information previously required under the EEOC’s EEO-1 Component 2 filings. The designated agency will be responsible for developing a reporting system and standardized form within a year of the law’s effective date. Employers will then have one year to submit their first reports and must file subsequent reports on an annual basis. Those who fail to comply risk civil penalties and being publicly listed on the agency’s website.

Additionally, the designated agency will conduct an annual pay equity study, analyzing the collected data to identify pay disparities and trends across industries and occupations. The agency will publicly release its recommendations, with any data presented in the aggregate to safeguard individual employee and employer identities.

Jackson Lewis is closely monitoring the status of these amendments and will provide updates as developments unfold.

If you have questions about New York City’s pending pay equity requirements and their potential impact on your organization, contact a Jackson Lewis attorney to discuss.

Beginning October 27, 2025, Cleveland employers with 15 or more employees will need to comply with the city’s new pay transparency and compensation history requirements. Ordinance No. 104-2025 prohibits covered employers from asking applicants about their salary history, including benefits, and bars employers from using compensation history to screen candidates or make hiring decisions. Employers must also include salary ranges or pay scales in all job postings.

The ordinance provides limited exceptions, such as internal transfers or promotions, voluntary and unprompted disclosures by applicants, or when compensation is governed by collective bargaining. The Fair Employment and Wage Board will enforce the new law. Upon receiving a complaint, employers will have 90 days to cure violations and may also appeal any civil penalties, which is more lenient than the five-business-day window employers have to cure deficiencies under the recent amendments to the Washington pay transparency laws.

With the compliance deadline rapidly approaching, now is the time for employers to act. Cleveland employers should take key steps:

  • Review and update all job postings to include salary ranges or scales.
  • Eliminate any application questions or interview practices that seek compensation history.
  • Train hiring managers and recruiters on compliance requirements.

If you have questions about Cleveland’s new requirements or aligning your hiring practices with evolving pay transparency laws nationwide, contact a Jackson Lewis attorney.

On September 26, 2025, Delaware Governor Matt Meyer signed House Substitute No. 2 to House Bill 105, adding Delaware to the growing list of states with pay transparency obligations for employers.

Beginning in 2027, employers will be required to include the pay range and a general description of benefits and other compensation in all job postings. The law applies to Delaware-based positions and certain remote roles offered by Delaware employers, with limited exceptions. Employers will also be subject to new recordkeeping requirements. The Delaware Department of Labor is tasked with enforcement and issuing regulations and administrative procedures.

Although the law does not take effect until 2027, employers may wish to prepare in advance. Reviewing job posting practices and updating compensation documentation may help ensure effective implementation and compliance when the new requirements take effect.

For guidance on how to navigate Delaware’s impending pay transparency requirements, or other states’ pay transparency laws, contact a Jackson Lewis attorney to discuss.

Washington State has taken a significant step for employers under its pay transparency law by giving employers a five-business-day grace period to correct violations in job postings and limiting the damages plaintiffs can win, among other changes to the law. The requirement that Washington employers post wage and salary information, and information about benefits and other compensation, in their job postings is unchanged.

On May 20, 2025, Governor Bob Ferguson signed legislation amending the state’s pay transparency law, the Equal Pay and Opportunities Act. The changes are effective July 27, 2025, through July 27, 2027.

Since the 2023 amendments went into effect requiring salary ranges and benefit disclosures in job postings, employers across the state have faced many lawsuits brought by so-called tester applicants, people applying not with the intent to work but to find technical violations. The new law introduces a grace period for employers to fix an identified issue. Under the new law, an employer notified in writing about a non-compliant job posting will have five business days to fix the issue before any penalties kick in.

Another welcome change for employers is the adjustment to the damages structure. Under the previous law, plaintiffs could claim damages automatically, regardless of intent or actual harm. The new law provides statutory damages ranging from $100 to $5,000, and courts are directed to consider several factors when determining awards, including the size of the employer, whether the violation was willful, and the nature of the infraction.

The amendments also clarify that employers are permitted to list a fixed rate, rather than a wage or salary range, when applicable. Additionally, employers will not be held liable for postings that are republished without their knowledge or consent by third-party websites.

Questions that remain include whether people applying solely to find non-compliant postings qualify as “bona fide applicants” and how the latest changes will affect pending litigation, if at all.

As we wait for more clarity, employers should continue to review their job postings carefully, implement internal compliance reviews and train HR teams on updated requirements. Employers should also have a plan for promptly addressing any potential violations. As always, Jackson Lewis attorneys are here to help you navigate these developments. Please reach out to our Pay Equity Group or the Jackson Lewis attorney you regularly work with for any questions.