Earlier this year, JVC informed you that the New York City Council had passed a bill requiring New York City employers with four or more employees to include the salary minimum and maximum for any advertised job, promotion, or transfer opportunity. Enforcement of this law will begin on November 1, 2022. Failure to comply with the pay transparency law will constitute an unlawful discriminatory practice, so any active job postings should be reviewed to ensure compliance. Westchester County recently passed a similarly-structured pay transparency ordinance, also for employers with four or more employees, which goes into effect on November 6, 2022.
In California, the governor recently signed into law a bill that imposes a variety of pay scale disclosure requirements that take effect on January 1, 2023. This includes:
- California employers with 15 or more employees must include in any job posting the salary or hourly wage range that the employer reasonably expects to pay
- All California employers must provide current employees the pay scale for their current position upon request
- All California employers must maintain records of the employee’s job title and wage rate history for the duration of employment plus three years after termination
Other states and localities may have additional pay transparency laws; check your state’s Department of Labor website for more information. Pay transparency laws promote equity in salaries and are intended to correct some of the historic pay imbalances that women and people of color have experienced over time.
For additional information or guidance on complying with pay transparency laws, please contact info@jvclegal.org or JVC members can schedule a chat on the JVC Member Portal with one of our attorneys.