Massachusetts Pay Transparency Law (2025): Compliance Guide for Employers

What Is the Massachusetts Pay Transparency Law?

Beginning October 29, 2025, Massachusetts employers with 25 or more employees must disclose pay ranges in job postings and provide them to applicants and employees upon request.

The law applies to:

• Full-time, part-time, seasonal, and temporary workers
• Remote employees whose primary workplace is Massachusetts
• Both public and private employers

Who Must Comply With the Massachusetts Salary Disclosure Requirements?

Employers with 25+ employees whose primary place of work is in Massachusetts must comply.

• Headcount is calculated annually by averaging employees across all pay periods.
• Applies to internal and external postings, including those made by third-party recruiters.

What Are the Key Compliance Requirements?

Job Postings

• All postings (internal, external, and third-party) must include the expected pay range.
  Applies to Massachusetts-based and remote roles.
• Ranges must reflect the specific opening, not the entire career progression.

Promotions & Transfers

• Employers must provide the pay range when offering promotions or transfers.

Employee Requests

• Current employees can request the pay range for their own position or roles they apply for internally.

What Are the Penalties for Noncompliance?

The Massachusetts Attorney General enforces the law. Penalties escalate with repeated violations:

What Employee Protections Exist?

The law prohibits retaliation against employees who:

• Request pay range information
• File a complaint
• Participate in enforcement proceedings

What Should Employers Do Before October 29, 2025?

Action Steps for HR & Business Leaders:

1. Document Pay Ranges – Create clear, defensible compensation structures.
2. Audit for Pay Equity – Identify and fix unjustified pay disparities.
3. Update Templates – Add pay range fields to job postings, offer letters, and recruiter instructions.
4. Train HR & Managers – Educate staff on compliance rules and anti-retaliation policies.
5. Establish Request Procedures – Set clear processes for handling employee pay range requests.

How Does Massachusetts Compare to Other States?

• California, New York, Washington, and Colorado have similar pay transparency laws.
• Colorado is stricter, requiring disclosure of both pay and benefits.
• Massachusetts is notable for extending requirements to internal promotions and transfers.

Additional Compliance Note

• Employers with 100+ employees must also submit annual EEO-1 reports to the Massachusetts Secretary of the Commonwealth by February 1.
• Official Guidance: Pay Transparency in Massachusetts | Mass.gov

Frequently Asked Questions (FAQ)

When does the Massachusetts Pay Transparency Law take effect?

The Massachusetts Pay Transparency Law takes effect on October 29, 2025.

Which employers must comply with the Massachusetts pay transparency law?

Employers with 25 or more employees whose primary place of work is in Massachusetts must comply. This includes remote workers based in Massachusetts.

What are the penalties for not complying with the Massachusetts Pay Transparency Law?

The Attorney General enforces the law. Penalties escalate: first offense is a warning, second offense up to $500 fine, third offense up to $1,000 fine, and fourth or subsequent offenses up to $25,000.

Do remote workers count toward the 25-employee threshold?

Yes. Remote employees are included if their primary workplace is Massachusetts.

Does the Massachusetts law apply to internal promotions and transfers?

Yes. Employers must disclose pay ranges for promotions and transfers, not just external job postings.

Need Help With Pay Transparency Compliance?

Our team is here to guide you through the Massachusetts Pay Transparency Law and ensure your business is fully compliant.

Please contact the NARFA Benefit Center with questions.