Where Posting Pay Is Required: A Pay Transparency Guide for Employers

A company posts one manufacturing role across several states.

The job title is the same. The responsibilities are the same. The posting goes live on the same day.

The employer assumes one version works everywhere.

That assumption can create problems.

Pay transparency rules vary by state and locality. Some require a pay range in the job posting. Some require benefits information as well. Others require disclosure only after an interview or when an applicant asks.

The rules also change based on:

• Where the work will be performed
• Whether the role can be performed remotely
• Employer headcount
• Whether the posting is public or internal
• The date the posting is published
• Local requirements in cities or counties

This is a general overview, not legal advice. Requirements change and may depend on your headcount, location, role, and hiring structure. Employers should confirm their obligations with counsel for each location where they hire.

The reference chart

Some states count total employees anywhere and only require a foothold in the state, while Massachusetts and Minnesota look at employees in the state. Colorado, Virginia, Maryland, D.C., and Connecticut set the bar so low that the headcount question rarely matters.

Crossing the threshold and deciding which postings must comply are separate tests. Once covered, the posting duty can reach roles performed in that state or remote roles reporting into it, so an employer can end up posting ranges on roles nowhere near the state that triggered coverage.

It is about where the work happens

Your headquarters may be in Florida.

That does not mean Florida rules are the only rules that matter.

Pay transparency requirements often follow where the work will be performed. This applies to jobs at a plant, warehouse, office, laboratory, or medical technology facility. It can also apply to remote roles connected to a particular state.

That creates practical questions:

• Can someone in Colorado perform the job?
• Is the remote role open to applicants in New York?
• Will the employee report to a facility in Illinois?
• Does the posting say “remote anywhere in the United States”?
• Is the role tied to a specific location, even if some work can happen remotely?

A broad remote posting can create a wider compliance footprint than an employer expects.

If you recruit nationally, the safest process is not to assume that one generic posting works everywhere. Review the locations where the role may be performed, then build the posting around the applicable requirements.

Some laws require more than a pay range

Posting a number is not always enough.

Several states also require a general description of benefits or other compensation. This includes Colorado, Maryland, Minnesota, New Jersey, Washington, and Illinois.

Depending on the location and role, the posting may need to address items such as:

• Salary or hourly range
• Commission or other compensation
• Benefits
• Bonuses or incentive pay
• Application deadlines
• Internal promotion opportunities

A few additional requirements are especially important for employers with manufacturing, quality, safety, and medtech roles.

Colorado

Colorado requires pay information in covered postings. It also requires an application deadline in postings.

Colorado can also reach remote positions that could be performed in the state. Employers should review remote language carefully instead of assuming that a national posting avoids the requirement.

Illinois

Illinois requires pay scale information in covered job postings. It also requires a general description of benefits and other compensation.

Illinois also requires employers to notify current employees of promotional opportunities within 14 calendar days after the job is posted externally.

That means recruiting teams need a process for coordinating public job advertisements with employee notifications.

Maine

Maine requires employers with 10 or more employees to include the prospective pay range in job postings.

It also has duties that go beyond the posting itself. Employers must provide the pay range for the position an employee already holds if the employee asks. Recordkeeping requirements also apply, and those duties apply to all Maine employers regardless of size.

Maine also already restricted salary history questions before the new posting law took effect. That part has been in place since 2019.

What changed in July 2026 is the posting requirement and the related duties tied to pay range disclosure and records.

Pay transparency and salary history rules are related, but they are not the same thing. A compliant hiring process needs to address both the posting and the questions asked during screening.

Virginia

Virginia’s job-posting requirement took effect July 1, 2026.

Virginia allows a private right of action for job-posting violations. It also allows a 15-business-day cure period for a defective posting.

Virginia also restricts asking about salary history.

Local laws can add another layer

State law is only part of the review.

Local requirements may apply in places such as:

• New York City
• Ithaca, New York
• Jersey City, New Jersey
• Columbus, Ohio
• Cleveland, Ohio
• Cincinnati, Ohio
• Toledo, Ohio

Ohio does not have a statewide pay transparency law in the information covered here. The city rules are not all the same.

Cleveland’s pay transparency rule has been in effect since October 27, 2025.

Columbus took effect December 3, 2025, but its job-posting requirement is delayed until January 1, 2027.

Cincinnati and Toledo are different. They are salary history bans, and the pay range comes into play only if an applicant asks after a conditional offer. They are not the same kind of proactive posting laws found in places like New York City or Cleveland.

This is one reason a location list should be part of the hiring process. A company may be compliant with state law and still miss a local requirement.

Build a range you can defend

The common standard is a good-faith pay range.

In simple terms, the range should reflect what the employer reasonably expects to pay for the role. It should connect to something real, such as:

• An established pay scale
• A previously determined range
• Pay for current employees in equivalent roles
• The approved budget for the position

A range that exists only to satisfy a posting requirement can create problems.

For example, an employer may post a range from $55,000 to $125,000 for a role it realistically expects to fill at $70,000 to $78,000. That range may technically look flexible, but it gives applicants little useful information.

Very wide ranges can also draw scrutiny. In New Jersey, for example, guidance flags ranges where the spread is more than 60 percent of the starting point.

It can also reduce response quality.

Candidates may apply because they expect the top of the range. Hiring managers may assume the range gives them room to negotiate. The result is more confusion at the end of the process.

A credible range should reflect the actual role.

Review:

• Scope of responsibility
• Required experience
• Shift and schedule
• Location
• Travel
• Supervisory responsibility
• Technical or regulatory requirements
• Internal pay equity
• Budget
• Bonus or incentive structure
• Benefits and other compensation

For manufacturing, safety, quality, and medtech positions, job scope often changes the range more than the title does. “Quality Manager” can mean one site, several facilities, supplier quality, validation, regulatory work, or full ownership of a quality system.

The posting should make that scope clear.

What this means when a recruiter posts on your behalf

Several of these laws may still apply when the posting is made by a third party instead of the employer directly.

That matters if you use an outside recruiter, agency, or job advertising partner. Minnesota is especially clear on this point, but it is a good working assumption in other covered locations too.

The safer approach is simple: if a posting may be covered, make sure the pay range and any other required details are handled before anyone publishes it.

A simple multi-state posting process

You do not need a complicated system. You do need a repeatable one.

1. Identify the work locations

List every state and locality where the employee may work.

Include remote locations. Do not rely only on the company headquarters.

2. Confirm coverage

Review headcount, entity structure, role location, and the type of posting.

If the law is unclear, ask counsel before publishing.

3. Set the range

Use a good-faith range tied to the budget, pay scale, internal equity, and actual scope of the role.

4. Add required information

Check whether the posting also needs:

• Benefits information
• Other compensation
• Application deadline
• Promotion notice or employee notification requirement
• Salary history restrictions in the screening process

5. Review the language

Avoid vague location statements such as “remote anywhere” unless the company is prepared to assess the resulting obligations.

Make the location clear. Make the role clear. Make the compensation clear.

6. Keep records

Save the approved range, job description, posting version, posting dates, and locations where the posting appeared.

A clean record helps when the range changes or a role is reposted.

The practical takeaway

Pay transparency is not only a legal checklist.

It is also a communication issue.

A clear range helps candidates decide whether the role is worth pursuing. It helps recruiters screen consistently. It gives hiring managers a firmer starting point. It reduces late-stage surprises.

But the range needs to be credible. The location needs to be accurate. The process needs to account for state and local rules.

No one posting automatically works everywhere.

Recruiter Theory helps companies build job postings, pay ranges, and hiring processes that hold up across locations. We can also help determine the right recruiting model for the situation, whether that means support for one difficult role, a broader recruiting function, or a more complete people operation.

No noise. Just a clear review of what you are hiring for, where you are hiring, and what needs to happen next.

This article is for general educational purposes only and is not legal advice. It reflects publicly available information as of September 2026 — pay transparency rules change often, and states and cities are added regularly. Requirements can also depend on employer size, where employees are located, role structure, and the exact language of a posting, and local ordinances may be stricter than state law. Reading this does not create an attorney-client relationship. Please confirm your obligations with qualified legal counsel before acting on anything here.