## Pay Transparency Laws Keep Expanding in 2026
As of 2026, nineteen states plus Washington D.C. require employers to disclose compensation in job postings or at hire. Most employers know California, New York, and Colorado — the early movers with high-penalty enforcement. But three additional states activated their pay transparency law requirements in 2025–2026, and remote-first hiring means you may already be subject to them.
Here's what changed, what's required, and why the compliance math gets complicated fast.
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Maine Pay Transparency Law: Effective January 1, 2026
Maine's pay transparency law took effect January 1, 2026, and applies to employers with **10 or more employees**. The requirement: include a pay range in every job posting, whether the posting appears on your career site, LinkedIn, Indeed, or any third-party job board.
**What counts as a compliant pay range?**
Maine defines a compliant disclosure as the salary or hourly wage range the employer "in good faith" expects to offer at the time the posting is created. It can be based on:
- An applicable pay scale
- A budgeted amount for the position
- A previously determined compensation range
- The actual wages paid to current employees in the same or comparable role
**Salary history is also off the table.** Maine prohibits employers from asking candidates about their wage history until after a conditional offer has been made. This applies to all employers, regardless of size.
**Wage data reporting:** Employers that file EEO-1, EEO-3, EEO-4, or EEO-5 reports federally must also submit wage data to the Maine Human Rights Commission — including median wages by job category, broken down by gender, race, and ethnicity.
**Penalty:** The Maine Human Rights Commission can investigate complaints and pursue civil enforcement. Violations can result in penalties up to $1,000 per violation, escalating for repeat or willful non-compliance.
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Oregon Pay Transparency Law (SB 906): Effective January 1, 2026
Oregon took a different approach. Instead of focusing on job postings, **Oregon SB 906** (signed May 28, 2025, effective January 1, 2026) requires employers to give every new hire a written explanation of how they will be paid — before the first paycheck arrives.
**What the disclosure must include:**
- The established regular pay period
- All types of pay rates the employee may earn (hourly, salary, shift differentials, piece-rate, commission)
- Every benefit deduction and contribution
- Every type of deduction that may apply, and its purpose
- Allowances claimed as part of minimum wage
- All payroll codes used on wage statements, with detailed descriptions
This is not a job posting rule — it's a hire-time requirement. **No small business exemption applies.** Every Oregon employer, regardless of size, must comply.
**Delivery:** The disclosure can be given as a hard copy, emailed, linked to a website, or posted physically — as long as the employee receives it at or before hire.
**Updates required annually:** Employers must review and update their disclosure every January 1 to reflect any changes to pay rates, deductions, or payroll codes.
**Penalty:** Oregon's Bureau of Labor and Industries (BOLI) can impose civil penalties of up to **$500 per violation** (assessed per employee affected, per audit finding). There is no private right of action, but BOLI actively investigates wage complaints.
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Vermont Pay Transparency Law: Effective July 1, 2025
Vermont's law is already in effect (since July 1, 2025) but many multi-state employers still haven't updated their templates. It applies to employers with **five or more employees** and requires every job posting — internal or external — to include a good faith pay range.
**Remote jobs are in scope:** If a position is remote but will "predominantly perform work for an office or work location physically located in Vermont," the job posting must include the pay range even if the worker isn't in Vermont.
**Promotions and transfers count:** Vermont's requirement extends to internal postings for current employees, not just external recruiting.
**Commission and tipped roles have modified rules:** Postings for commission-only roles must state that fact. Postings for tipped positions must disclose that the role is tipped and provide a good faith range of the base (non-tip) wages.
**Enforcement:** Vermont's Attorney General's Civil Rights Unit handles complaints. Penalties run up to $1,000 per non-willful violation and up to $10,000 per willful violation. Employers that posted in good faith but ultimately offered pay outside the posted range are not automatically in violation — the AG's guidance allows for adjustments based on market conditions or candidate qualifications, provided there's documented justification.
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The Remote Job Posting Problem
Here's where compliance gets expensive: **one remote job posting can trigger three or more states simultaneously.**
Consider an employer headquartered in Texas posting a "remote — US" role. If that job is open to applicants in Colorado, California, New York, Maine, Vermont, or Washington, the employer must comply with each state's requirements in the same posting.
Under **Colorado's EPEWA**, that means including not just the pay range but also a description of benefits. Under **New York City's law**, the range must reflect the rate for employees who will work in New York City. Under **Maine's law**, the range must appear in the posting itself (not just "available upon request"). These requirements don't resolve to a single template.
The multi-state remote posting problem is one of the most common compliance failures. HR teams often know one state's rules well but miss the others — and penalties stack per violation, per job posting.
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States Still Activating in 2026
Vermont, Maine, and Oregon are already live, but the pipeline continues:
- **Minnesota** — Pay equity reporting requirements are expanding in 2026 for employers with state contracts (effective January 1, 2026 for new contract solicitations)
- **New Jersey** — Active enforcement ramp-up in 2026 after the 2024 law; fines of $300–$600 per violation
- **Massachusetts** — 2025 law covers employers with 25+ employees; $500–$25,000 fines, with a 2-business-day cure notice
If your company hires across state lines — or posts remote roles — you need to track these deadlines on an ongoing basis. At least three more states have pay transparency bills in committee as of Q1 2026.
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Penalties Across Key States
| State | Employer Threshold | Penalty Range | Enforcement | |---|---|---|---| | California | 15+ employees (job postings) | $100–$10,000/violation | CA Civil Rights Dept. | | New York | 4+ employees | $1,000–$25,000/violation | NY DOL | | Colorado | 1+ employees | $500–$10,000/violation | CO DLSS | | Illinois | 15+ employees | $250–$10,000/violation | IL Dept. of Labor | | Maine | 10+ employees | Up to $1,000/violation | ME Human Rights Comm. | | Vermont | 5+ employees | $1,000–$10,000/violation | VT AG Civil Rights Unit | | Oregon (SB 906) | All employers | Up to $500/violation | Oregon BOLI | | Massachusetts | 25+ employees | $500–$25,000/violation | MA AG Office |
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What to Do Now
**1. Audit your job posting templates.** If you have a standard external posting template and a separate internal posting template, both need to be checked. If either is used for remote roles, it must comply with the most restrictive applicable state.
**2. Update your onboarding packet for Oregon.** If you hire anyone in Oregon, you need a pay transparency disclosure document that covers pay rates, deduction types, and payroll codes. Build the template before you hire — not after.
**3. Map your remote applicant states.** If you accept applications from employees in any state — or have remote workers in multiple states — document which laws apply and create a compliance matrix.
**4. Check your threshold math.** These laws count employees differently: Maine counts all employees nationally (FTE and part-time) toward its 10-employee threshold. Vermont counts all employees wherever located. Oregon has no employee threshold — it applies to every employer. A company with 8 US employees and 4 in Maine is subject to Maine's law even if it has no Maine office.
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Tracking 17+ States in One Place
The pay transparency law landscape changes every year. Maine and Oregon activated their requirements on January 1, 2026. Vermont's law took effect July 1, 2025. Several more states have active bills pending in 2026 legislatures.
Regulatr's [pay transparency compliance tool](/pay-transparency) tracks active requirements across all 17+ states, flags when your job postings are missing required disclosures, and sends alerts when new laws take effect or penalty thresholds change. If you're posting remote roles, it checks multi-state exposure in one step.
One job posting with the wrong salary range in New York costs more than years of subscription fees.