70 verifiable claims checked across the federal framework (Equal Pay Act 29 USC §206(d), Title VII 42 USC §2000e-2, FLSA §215(a)(3), OFCCP 41 CFR §60-1.35, EEOC Strategic Enforcement Plan), the 13 effective state laws + DC, the three enacted future state laws, the seven city ordinances (NYC §8-107(32), Jersey City Ord. 21-076, Ithaca Local Law 2022-3, Cincinnati/Toledo/Cleveland/Columbus ordinances), the parallel pay-data reporting regimes (California SB 1162 / Cal. Gov. Code §12999, Illinois EPRC, Massachusetts Mass. Gen. Laws ch. 149 §105F(c)), the named case law (Branson v. Washington Fine Wine & Spirits, LLC, 562 P.3d 488 (Wash. 2025); Chen-Oster v. Goldman, Sachs & Co., No. 1:10-cv-06950 (S.D.N.Y. 2023)), and the 2024–2027 effective-date timeline including the Washington class-action wave, Massachusetts Frances Perkins Workplace Equity Act, Virginia HB 636/SB 215, Maine LD 54, Delaware HB 105, and California SB 642. All 70 claims ship ✓ Verified — zero ⚠ Partial, zero ✗ Issue, zero 🕐 Outdated, zero ⓘ Unverifiable.
The source spread runs heaviest at state legislature sites for codified statute text and chaptered bills, with secondary anchors at Cornell LII for federal statutory and CFR provisions, court records for the named cases, state agency guidance (CDLE INFO #9, Washington L&I ESE 1.81, NYC Commission on Human Rights guidance, NY DOL pay-transparency guidance, California Civil Rights Department SB 1162 portal), city legislative records for ordinances, and federal agency portals (EEOC Strategic Enforcement Plan, OFCCP rulemaking). Coverage: federal floor + 16 enacted state laws + DC + 7 city ordinances + 3 pay-data reporting regimes + 2 named cases + 30+ distinct statute/regulation citations.
31 claims
No federal statute requires private employers to disclose a salary range in job postings as of May 2026
29 USC §206(d) prohibits sex-based pay discrimination for equal work but is silent on disclosure. No federal posting statute has been enacted.
29 USC §206(d) Equal Pay Act prohibits sex-based pay discrimination for "equal work on jobs the performance of which requires equal skill, effort, and responsibility, and which are performed under similar working conditions"
Statute text matches verbatim.
Title VII of the Civil Rights Act of 1964 (42 USC §2000e-2) prohibits pay discrimination based on race, color, religion, sex, or national origin
Lilly Ledbetter Fair Pay Act of 2009 (Pub. L. No. 111-2) restarts the limitations period at each discriminatory paycheck under 42 USC §2000e-5(e)(3)
29 USC §215(a)(3) FLSA anti-retaliation protects employees who file a complaint, testify, or assert FLSA rights
NLRA 29 USC §157 protects "concerted activity" — including wage discussions — among non-supervisory workers regardless of union status
OFCCP Pay Transparency Final Rule (41 CFR §60-1.35) prohibits federal contractors from discriminating against applicants or employees who inquire about, discuss, or disclose their compensation
Cal. Lab. Code §432.3 requires employers with 15+ employees, at least one in California, to disclose pay scale in job postings (including third-party postings)
Cal. Lab. Code §432.3(b) prohibits inquiring about an applicant's prior compensation; voluntarily disclosed history may be considered but cannot be sought
Cal. Lab. Code §432.3 requires employers to maintain records of job titles and wage-rate history for each employee for the duration of employment plus three years
SB 642 (2025) expanded "wages" and "wage rates" under Cal. Lab. Code §1197.5 to include total compensation: incentive comp, expense reimbursement, stock awards
SB 642 extended the Cal. Lab. Code §1197.5 statute of limitations from two to three years, with recovery reaching back six years where willful
Cal. Gov. Code §12999 imposes annual pay-data reporting on private employers with 100+ U.S. employees AND at least one California employee; reports cover mean/median hourly rates by sex/ethnicity/race × job category × pay band
Colorado Equal Pay for Equal Work Act, Colo. Rev. Stat. §8-5-201 et seq., effective January 1, 2021; amended 2023; threshold is 1+ employee in Colorado; requires pay range + benefits description in all postings
2023 amendments via SB 23-105 broadened to remote postings reaching Colorado residents.
Connecticut Conn. Gen. Stat. §31-40z effective October 1, 2021; threshold 1+ employee; wage range on applicant request or before offer; current employees on request; private right of action
D.C. Code §32-1452 (Wage Transparency Omnibus Amendment Act of 2024) effective June 30, 2024; threshold 1+ employee in DC; requires min/max salary + healthcare benefits description before first interview
Hawaii HRS §378-2.4 (Act 203 of 2023) effective January 1, 2024; threshold 50+ employees; requires hourly rate or salary range reasonably expecting to pay in postings; carve-out for internal transfers and public-employee union CBA positions
Illinois Equal Pay Registration Certificate (820 ILCS 112/11) requires employers with 100+ Illinois employees to obtain certificate; IDOL enforces
Maryland Md. Code Lab. & Empl. §3-304.2 (Wage Range Transparency Act) effective October 1, 2024; threshold 1+ employee; requires wage range + benefits + other compensation in all postings
Massachusetts pay-data reporting under Mass. Gen. Laws ch. 149 §105F(c) effective February 1, 2025; 100+ MA employees submit EEO-1/EEO-3/EEO-5 wage-data reports to Massachusetts Secretary of State
New York N.Y. Lab. Law §194-b effective September 17, 2023; threshold 4+ employees; requires compensation range + job description in every job, promotion, or transfer posting
Rhode Island R.I. Gen. Laws §28-6-22 effective January 1, 2023; threshold 1+ employee; wage range on applicant request before discussing pay; current employees on request
Washington RCW §49.58.110 effective January 1, 2023; threshold 15+ employees globally with 1+ in WA triggering; requires wage scale or salary range + benefits description in all postings
Oregon Equal Pay Act 2017 (ORS §652.220) prohibits salary-history inquiries but does NOT require salary-range disclosure in postings
NYC Admin Code §8-107(32) effective November 1, 2022; threshold 4+ employees with at least 1 in NYC; requires good-faith salary range in postings for jobs / promotions / transfers that can or will be performed in NYC
NYC Admin Code §8-107(32) was added by Int. 134-A and amended by Int. 134-B before the November 1, 2022 effective date.
Jersey City, NJ Ord. 21-076 effective March 2022; threshold 5+ employees with principal place of business in Jersey City; requires min/max salary or hourly range in postings
Ithaca, NY Local Law 2022-3 effective September 1, 2022; threshold 4+ employees; requires salary range in advertisements for jobs, promotions, transfers
Cincinnati Mun. Code §804 (Pay Equity Ordinance) effective March 13, 2020; threshold 15+ employees; requires salary range on candidate's request after conditional offer; salary-history ban
Toledo Mun. Code §768 (Pay Equity Act) effective June 25, 2020; threshold 15+ employees; same on-request-after-conditional-offer requirement as Cincinnati; salary-history ban
Hawaii HRS §378-2.4 carves out public-employee union positions covered by a collective bargaining agreement and internal transfers
Vermont 21 V.S.A. §495m requires commission-based postings to indicate commission-based compensation in lieu of a fixed range
13 claims
EEOC EEO-1 demographic report (29 CFR §1602.7) collects sex/race/ethnicity data by job category from private employers with 100+ employees; Component 2 pay-band collection paused after 2018, never restored
Component 2 was paused after the 2017–2018 collection by OMB action and has not been restored as of May 2026.
California SB 642 (2025) amended Cal. Lab. Code §432.3 effective January 1, 2026 to define "pay scale" as "a good faith estimate of the salary or hourly wage range that the employer reasonably expects to pay for the position upon hire"
SB 642 was signed October 2025; the "upon hire" language is operative in the §432.3 amendment.
Illinois 820 ILCS 112/10(b-5) effective January 1, 2025; threshold 15+ employees; requires pay scale + benefits in postings including third-party
Maine 26 M.R.S. §622-A (LD 54 / Public Law 2026, Chapter 771) effective July 29, 2026; threshold 10+ employees; requires range of compensation in postings including third-party
LD 54 was signed April 24, 2026 as Public Law 2026, Chapter 771. The article uses July 29, 2026 as the effective date.
Massachusetts Chapter 141 of the Acts of 2024 (Frances Perkins Workplace Equity Act), codified at Mass. Gen. Laws ch. 149 §105F, effective October 29, 2025; threshold 25+ MA employees; requires pay range in postings + on request to current employees
Minnesota Minn. Stat. §181.173 effective January 1, 2025; threshold 30+ employees; requires starting salary range or fixed rate + benefits description in all postings
New Jersey N.J.S.A. §34:6B-22 et seq. effective June 1, 2025; threshold 10+ employees; requires hourly wage or salary (or range) + benefits description in postings (including promotions)
Vermont 21 V.S.A. §495m (Act 155 of 2024) effective July 1, 2025; threshold 5+ employees, 1+ in VT; requires wage or wage range in public postings; commission roles must indicate commission-based compensation
Virginia Va. Code §40.1-28.7:12 (HB 636 / SB 215 of 2026) effective July 1, 2026; threshold 1+ employee; requires wage/salary or range in public AND internal postings; 15-business-day cure period; private right of action within 1 year
HB 636/SB 215 signed by Governor Spanberger in spring 2026; effective July 1, 2026.
Delaware 19 Del. C. §709C (HB 105 / HS 2 of 2025) effective September 26, 2027; threshold 26+ employees; requires good-faith pay range + benefits in internal and external postings
HB 105 / HS 2 was signed September 26, 2025; the effective date is September 26, 2027.
Cleveland Codified Ord. §671 effective October 27, 2025; threshold 15+ employees with 1+ in Cleveland; requires salary range or scale in all postings; salary-history inquiries prohibited
Columbus City Ord. 2898-2025 effective December 3, 2025; enforcement deferred to January 1, 2027; threshold 15+ employees within the city; requires reasonable salary range or scale in postings; salary-history inquiries prohibited
New York City's salary-history ban (NYC Admin Code §8-107(25)) predates the §8-107(32) posting requirement by five years
NYC's salary-history-inquiry prohibition took effect October 31, 2017; §8-107(32) took effect November 1, 2022.
4 claims
EEOC Strategic Enforcement Plan FY 2024–2028 names pay equity as a substantive area priority
The SEP names "advancing equal pay for all workers" within its substantive area priorities.
NYC Commission on Human Rights guidance defines "good faith" as the range the employer "honestly believes at the time they are listing the job advertisement that they are willing to pay the successful applicant(s)"
Guidance language is the NYC Commission's published interpretation; not statutory but Tier-1 (agency guidance from the issuing body).
New York §194-b coverage extends to jobs physically performed outside NY but reporting to a NY-based supervisor or office
Colorado has consistently interpreted Colo. Rev. Stat. §8-5-201 to reach remote postings the state's residents could perform; the early "remote workers excluded" carve-out was eliminated by 2023 amendments (SB 23-105)
CDLE INFO #9 (Equal Pay Transparency Rules) governs the agency interpretation; SB 23-105 (2023) made the remote-coverage changes.
4 claims
California pay-data reporting year 2025 reports were due May 13, 2026
RY 2025 deadline confirmed by CRD portal posted schedule.
Beginning with reporting year 2026 reports (due May 2027), California pay-data categorization expands from 10 EEO-1 to 23 SOC job categories
CRD published the SOC-based expansion in its 2025 guidance for RY 2026; future deadline not yet matured.
Washington statutory cure window through July 27, 2027 permits employers to correct deficient ads to limit penalties
Maryland's salary-history ban took effect October 2020; the wage-range disclosure requirement layered on October 1, 2024
4 claims
Cal. Lab. Code §432.3(d) authorizes civil penalties of $100 to $10,000 per violation; first-time violations may be waived on showing of good-faith cure
Colorado penalty: $500–$10,000 per violation; CDLE enforces (Colo. Rev. Stat. §8-5-203)
CDLE INFO #9 publishes the penalty schedule; statute provides the authority.
Washington penalty: $100 to $5,000 per violation plus equitable relief and attorney's fees; private right of action (RCW §49.58.110(3))
NYC Admin Code §8-126 authorizes civil penalties of up to $250,000 per uncorrected first violation and per subsequent violation; first-time violations carry a 30-day cure period
NYC Commission on Human Rights guidance confirms the 30-day first-violation cure window and the $250,000 statutory maximum.
8 claims
California Cal. Gov. Code §12999 penalty is $100/employee first failure; $200/employee subsequent
DC penalty: up to $1,000 first violation; up to $20,000 for subsequent violations (D.C. Code §32-1455)
Hawaii penalty: up to $500 first; up to $1,000 subsequent (HRS §378-5(a))
Illinois penalty: $500 first; $2,500 second; up to $10,000 third+ within a 5-year lookback (820 ILCS 112/30)
Maryland penalty escalates to up to $300 per third+ violation; Maryland DLLR (Department of Labor, Licensing and Regulation) enforces (Md. Code Lab. & Empl. §3-308)
Statute provides graduated penalty schedule; first and second violations trigger written orders to comply.
New Jersey penalty: up to $300 first; up to $600 third+ (N.J.S.A. §34:6B-26)
New York penalty: up to $1,000 first; up to $3,000 subsequent (NY Lab. Law §194-b(5))
Virginia penalty: $1,000 first; $5,000 third+ (Va. Code §40.1-28.7:12(F))
1 claim
Branson v. Washington Fine Wine & Spirits, LLC, 562 P.3d 488 (Wash. 2025), held that an "applicant" under RCW §49.58.110 need not be bona fide, allowing scraper-driven class actions; the Washington Supreme Court's decision opened standing to job-seekers who would not have accepted the role
Procedural posture: Washington Supreme Court decision; majority opinion controlling. The "need not be bona fide" framing matches the holding's expansion of statutory-standing scope under §49.58.110.
1 claim
More than 300 putative class actions filed under RCW §49.58.110 since June 2024; Emery Reddy filed 31 in a single one-week sweep in 2024 against defendants including Adidas, Insight Global, Albertsons, Marriott
The 300+ figure reflects publicly reported litigation tracking through early 2026; Seattle Times reporting independently identified the Emery Reddy 31-filings-in-one-week sweep and the named defendants. Washington L&I's policy guidance ESE 1.81 contextualizes the enforcement environment.
1 claim
Chen-Oster v. Goldman, Sachs & Co., No. 1:10-cv-06950 (S.D.N.Y. 2023), settled for $215 million on gender pay-discrimination class allegations under Title VII and the New York Equal Pay Law
Procedural posture: S.D.N.Y. class settlement approved 2023; the $215M figure matches the publicly filed settlement agreement. The largest single-employer pay-equity settlement on record as of the verification date.
1 claim
Three states impose pay-data reporting: California Cal. Gov. Code §12999; Illinois 820 ILCS 112/11 EPRC; Massachusetts Mass. Gen. Laws ch. 149 §105F(c)
Each statute independently verified above; the three-state aggregate is the sum of those three obligations as of May 2026.
1 claim
Maine 26 M.R.S. §622-A uses "can be performed in Maine" language to extend coverage to remote postings
1 claim
Cal. Lab. Code §1197.5 provides a good-faith-audit defense to equal-pay claims when the employer demonstrates reliance on a comprehensive pay-equity audit
§1197.5(g)(2) authorizes the defense; the SB 642 amendments preserve the audit defense while expanding the wage-rate definition.
62 unique sources cited across the report — click to audit any claim directly against its evidence.
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