Overview
Starting on October 29, 2025, employers subject to Massachusetts’ Wage Transparency Act (formally known as An Act Relative to Salary Range Transparency) must include the applicable pay range in all job postings for positions located in Massachusetts. This requirement applies to both internal and external postings, including those made through third parties, such as recruiters or job boards. It also covers positions that can be performed remotely and that report to a Massachusetts worksite, along with remote workers with a primary place of work in Massachusetts.
In Depth
Background
On July 31, 2024, Massachusetts Governor Maura Healey signed the Wage Transparency Act into law. The act, which follows similar statutes enacted in more than a dozen other states, imposes new disclosure and reporting obligations on most employers in the commonwealth. The two central employer mandates under the act are 1) disclosing pay ranges in job postings and to employees and applicants, and 2) reporting wage data to the secretary of the commonwealth.
Pay range disclosure
The Wage Transparency Act’s pay range disclosure requirements apply to employers with 25 or more employees whose primary place of work is Massachusetts. Coverage extends to both private and public employers and encompasses all forms of employment, including full-time, part-time, seasonal, and temporary workers. The act defines pay range as the “annual salary range or hourly wage range that the Covered Employer reasonably and in good faith expects to pay for a position at the time.”
In addition to job postings, employers are required to disclose the applicable pay range to employees and applicants when they apply for a position, are promoted or transferred, or begin a new role, as well as upon request for their existing position.
Wage data reporting
Separate from the job posting requirement, the Wage Transparency Act requires larger Massachusetts employers to report pay data. Any employer with 100 or more employees that is required to file federal Equal Employment Opportunity (EEO) data reports (e.g., EEO-1 reports), must submit a copy of its reports annually to the secretary of the commonwealth. The first report was due on February 1, 2025, and subsequent filings must be made each year thereafter. Although the commonwealth will not release employer-specific data to the public, the secretary is authorized to publish aggregated and anonymized data showing trends in pay equity and workforce composition across industries and regions.
Penalties
Employers that violate the act may face penalties ranging from a warning to civil fines of up to $25,000 per violation, depending on the severity and frequency of the offense. For the first two years after the act takes effect, employers will have two business days to cure any defects upon receiving a notice of violation before fines are imposed. The act also prohibits retaliation against employees or applicants who exercise their rights under the statute.
Act now
Given the imminent effective date for the Wage Transparency Act’s compensation disclosure obligations, employers should consult with legal counsel to ensure that all internal and external job postings comply with the statute’s mandates and prepare accurate pay data reports for submission to the secretary in 2026.