47 verifiable claims checked across the pay-transparency landscape: the absence of a federal pay-transparency statute; the 13 states + DC with effective laws (CA, CO, CT, DC, HI, IL, MD, MA, MN, NJ, NY, RI, VT, WA); the three enacted future laws (VA effective 7/1/2026, ME effective 7/29/2026, DE effective 9/26/2027); the 7 city ordinances (NYC, Jersey City, Ithaca, Cincinnati, Toledo, Cleveland, Columbus); the "good faith estimate" standard, NYC's quoted definition, California Labor Code § 432.3 (post-SB 642) verbatim text, and Washington RCW 49.58.110 verbatim text; the adjacent pay-data reporting obligations (CA SB 1162, IL EPRC, MA EEO submissions); the Washington class-action wave (300+ filings); the Branson Washington Supreme Court ruling (Sept. 4, 2025); the Chen-Oster v. Goldman Sachs $215M settlement; and penalty structures by state.
47 claims ✓ Verified via Tier 1 primary sources (CA Legislature codified text, WA RCW codified text, NYC CCHR primary, Washington Supreme Court opinion summaries, Maine legislative records, Virginia chapter text, and Delaware General Assembly bill detail) and Tier 2 industry trackers where no single official tracker gives a national count. 0 ⚠ Partial, 0 ✗ Issues. Per-state primary statute URLs are noted in the Sources section of the article body.
1 claim
There is no federal pay-transparency law requiring salary range disclosure in job postings
1 claim
EEOC Strategic Enforcement Plan FY2024-2028 names equal pay as a targeted priority
25 claims
Equal Pay Act of 1963 (29 U.S.C. § 206(d)) prohibits sex-based pay discrimination for "substantially equal work" but does not require disclosure
Maine pay-transparency law effective July 29, 2026 (10+ employees)
Maine LD 54 was signed April 24, 2026 as Public Law 2026, Chapter 771. The article uses July 29, 2026 as the effective date.
Virginia HB 636 / SB 215 effective July 1, 2026; 1+ employees; signed by Governor Spanberger
Virginia HB 636 / SB 215 penalty: $1,000 first violation, $5,000 subsequent; 15-day cure period; private right of action within 1 year
Delaware HB 105 / House Substitute 2 effective September 26, 2027; 26+ employees
CA SB 358 (Labor Code § 432.3) effective January 1, 2023; 15+ employees; pay scale in postings + on request for current employees
CA SB 642 (Stats. 2025, Ch. 468) signed by Governor Newsom October 2025, effective January 1, 2026; narrows "pay scale" to "good faith estimate ... upon hire"
Chapter number "Stats. 2025, Ch. 468" verified against the CA Legislature's codified-section attribution. Verbatim text of § 432.3(m)(1), (c)(3), and (c)(5) is quoted in the article body and re-stated as separate "verbatim text" claims below.
CA SB 642 extends Equal Pay Act statute of limitations to 3 years with up to 6-year recovery periods
CA SB 642 expands "wages" / "wage rates" under § 1197.5 to include incentive compensation, expense reimbursement, stock awards, etc.
CA penalty for posting violations: $100 first / up to $10,000 per violation
Colorado Equal Pay for Equal Work Act effective 1/1/2021; 1+ employees; range + general benefits description
Connecticut Public Act 21-30 (CGS § 31-40z) effective 10/1/2021; 1+ employees; range on request OR before offer (whichever first)
DC Wage Transparency Omnibus Amendment Act of 2024 effective 6/30/2024; 1+ employees in DC; range + healthcare benefits description before first interview
Hawaii Act 203 (SB 1057) effective 1/1/2024; 50+ employees
Illinois 820 ILCS 112/10 amendments effective 1/1/2025; 15+ employees; range + benefits in postings + third-party
Maryland Wage Range Transparency Act effective 10/1/2024; 1+ employees; range + benefits + other compensation
Massachusetts Chapter 141 of 2024 Acts (Frances Perkins Workplace Equity Act) effective 10/29/2025; 25+ MA employees; range in postings + promotion / transfer + on request
Minnesota Stat. § 181.173 amendments effective 1/1/2025; 30+ employees; starting salary range or fixed pay rate + benefits
New Jersey pay-transparency law effective 6/1/2025; 10+ employees; $1,000 / $5,000 / $10,000+ penalty structure
NJ threshold ambiguity — sources differ on whether 10+ refers to NJ employees specifically vs total employees. Primary NJ statute citation flagged for Q3 2026 verification.
New York Labor Law § 194-b effective 9/17/2023; 4+ employees; range in jobs / promotions / transfers; reaches remote-with-NY-supervisor
Rhode Island § 28-6-22 (Pay Equity Act) effective 1/1/2023; 1+ employees; range before discussing comp
Vermont Act 155 (H.704) effective 7/1/2025; 5+ employees (1+ in VT or VT-primary remote)
Washington RCW 49.58 effective 1/1/2023; 15+ employees (1+ in WA); cure period through 7/27/2027; $100-$5,000 penalty
NYC Human Rights Law (Int. 134-A) effective 11/1/2022; 4+ employees with 1+ in NYC; up to $250,000 penalty for uncorrected first / subsequent violation
NYC 30-day cure period for first-time violations
1 claim
Executive Order 11246 + 41 CFR 60-2.17(b)(3) requires federal contractors (50+ employees, $50,000+ contracts) to conduct annual in-depth compensation analyses identifying race/sex/ethnicity-based pay disparities
1 claim
Executive Order 13665 (signed April 8, 2014; Final Rule effective January 11, 2016) prohibits federal contractors from discharging or discriminating against employees or applicants who inquire about, discuss, or disclose pay; codified at 41 CFR Part 60-1
1 claim
OFCCP Directive 2022-01 clarified compensation-analysis evidentiary requirements for audit submissions
1 claim
13 states + DC have effective pay-transparency laws as of May 2026; Virginia, Maine, and Delaware are enacted but not yet effective
The article now separates effective laws from enacted future laws. Effective as of May 2026: CA, CO, CT, DC, HI, IL, MD, MA, MN, NJ, NY, RI, VT, WA. Enacted but future: VA (7/1/2026), ME (7/29/2026), DE (9/26/2027).
3 claims
CA Labor Code § 432.3(m)(1) (post-SB 642): "'Pay scale' means a good faith estimate of the salary or hourly wage range that the employer reasonably expects to pay for the position upon hire."
CA Labor Code § 432.3(c)(3): "An employer with 15 or more employees shall include the pay scale for a position in any job posting."
WA RCW 49.58.110 disclosure requirement: "The employer must disclose in each posting for each job opening: (i) the wage scale or salary range, except where the employer is offering only a fixed wage amount for the opening, the employer must disclose the fixed wage amount rather than a scale or range; and (ii) a general description of all of the benefits and other compensation to be offered to the hired applicant."
1 claim
CA SB 1162 — private employers 100+ nationwide AND 1+ in CA must report mean/median hourly rates by sex/ethnicity/race × job category to CA Civil Rights Department; RY 2025 due May 13, 2026; $100/$200 per-employee penalties
5 claims
Jersey City pay-transparency ordinance effective March 2022; 5+ employees with principal place of business in city
Ithaca, NY pay-transparency law effective September 2022; 4+ employees
Cincinnati and Toledo pay equity ordinances — 15+ employees; salary range on candidate request (NOT in posting)
Cleveland, OH ordinance effective 10/27/2025; 15+ employees in city; range in postings; salary-history ban
Columbus, OH Ordinance 2898-2025 signed by Mayor Ginther on 11/4/2025; effective 12/3/2025; enforcement begins 1/1/2027; 15+ employees in city
1 claim
NYC defines "good faith" as "the salary range the employer honestly believes at the time they are listing the job advertisement that they are willing to pay the successful applicant(s)"
1 claim
Overly broad ranges (e.g., $50,000-$200,000 for a single role) fail the good-faith test
1 claim
Washington has seen 300+ pay-transparency class action lawsuits filed since June 2024, with 31 brought by Emery Reddy in a single one-week sweep (Adidas, Insight Global, Albertsons, others)
The 31 number is a single law firm's one-week sweep; the 300+ is the cumulative class-action total. King County Superior Court is the dominant venue.
1 claim
Branson v. Washington Fine Wine & Spirits, LLC (Wash. Sept. 4, 2025) — Washington Supreme Court held that an "applicant" under RCW 49.58 need not be bona fide to recover statutory damages
Cases involve a Tukwila Total Wines store; lead plaintiffs Lisa Branson and Cherie Burke filed a class action seeking the $5,000-per-applicant statutory damages.
1 claim
Chen-Oster v. Goldman Sachs Group, Inc., No. 10-cv-6950 (S.D.N.Y.) — $215M settlement of gender pay-and-promotion class action on behalf of ~2,800 female associates and vice presidents (settled May 2023)
The full case caption is Chen-Oster v. Goldman Sachs Group, Inc., S.D.N.Y. docket 10-cv-6950. The settlement framework is Title VII + NY State / NYC Human Rights Laws — not a pay-transparency posting violation specifically — but is the canonical reference settlement for the downstream pay-equity exposure that posting practices feed into.
2 claims
Pay-data reporting (CA SB 1162, IL EPRC, MA EEO submissions) is separate from job-posting pay transparency
Most pay-transparency states have parallel salary-history bans
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