Webinar - Pay transparency legislation in 2025: A year-end roundup and the road ahead

Join Payscale experts for our final pay transparency legislation webinar of the year where we’ll look back at the major legislative developments that shaped 2025 and look forward to what’s on the horizon in 2026 and beyond.

1. Pay Transparency
Legislation in 2025: A
year-end roundup and
the road ahead

2. Today’s presenters
Ruth Thomas
Chief Compensation
Strategist
Lulu Seikaly
Senior Corporate Attorney-
Employment

3. Agenda
•Pay Transparency legislation update:
•US
•Canada
•Europe
•UK
•How to prepare for EU Pay Transparency Compliance
•Q&A
10:00 – 11:00All – Ruth lead

4. A.Only where required – We comply with legislation in jurisdictions that
mandate it, but not beyond that.
B.Uniform approach – We’ve adopted a consistent pay transparency
policyacross all locations, regardless of legal requirement.
C.Hybrid model – We meet legalobligations where required and are
piloting broader transparency practices elsewhere
D.Stillevaluating –We're currently assessing our approach and haven't
implemented a specificstrategy yet.
E.Unsure
Poll 1: How is your organization
approaching compliance with pay
transparency legislation?

5. Canada: Mainly province led efforts
US: state-by-state progress
LATAM: - Low regulatory activity
but growing awareness
EU: Heating up ahead of June 26
EU Directive deadline
UK: Considering
alignment with EU
APAC: Emerging interest
but most voluntary
Global Pay Transparency

6. North America

7. Pay Transparency US Legislative landscape

8. •Who: employers with 10 or more employees (anywhere) doing business
in New Jersey.
•What:wage or salary or wage or salary range + general description of
benefits and other compensation
•E.g. bonuses, stock options, or other incentives
•Applies to internal promotions/transfers (except promotions based on
performance/tenure or emergency situations)
•Proposed Penalties:$300 first offense and up to $600 for each
subsequent offense.
New Jersey
Effective: June 1, 2025

9. •Who: employers with 5 or more employees, with at least 1 working in
Vermont, for job postings required to be physically performed in Vermont
or a remote job that is predominantly performed in a Vermont office or
other Vermont location.
•What:minimum and maximum annual salary or hourly wage that the
employer in “good faith” expects to pay for the role.
•Commissioned Jobs: if role is paid entirely or partly on commission,
only needs to state that and no need to disclose compensation
range.
•Tipped Jobs: must disclose this + range of base wages.
•Proposed Penalties:Vermont AG will enforce this law.
Vermont
Effective: July 1, 2025

10. •Who: employers with 25 or more employees in the Commonwealth
•Applies to remote work.
•What:must post the annual salary range or hourly range that the
employer “reasonably and in good faith” expects to pay for a position at
the time of posting.
•Applies to internal promotions/transfers.
•Employers must provide this information upon request to incumbent
employees for their current role.
•Proposed Penalties:warning for first offense; $500 for second offense;
$1,000 for third offense; etc.
Massachusetts
Effective: October 29, 2025

11. •Who: employers with 15 or more employees operating in the City of
Cleveland.
•Applies to roles where the work is to be performed in Cleveland or
where the application is “solicited, received, processed, or
considered” in Cleveland (even if interview is remote).
•What:must post the salary range in job postings.
•Applies to internal transfers/promotions
•Salary history ban in place
•Proposed Penalties:90 day cure window, then penalties from $1,000-
$5,000 per violation.
Cleveland, Ohio
Effective: October 27, 2025

12. •Who: employers with 25 or more employees
•Applies to remote work for Delaware-based employers.
•What:must post the annual salary range or hourly range that the
employer “reasonably and in good faith” expects to pay for a position at
the time of posting + general description of benefits and other comp.
•Proposed Penalties:. warning for first offense; $500 for second offense;
$1,000 for third offense; etc
Delaware
Effective: September 26, 2027

13. •Five-Day Cure Period: employers have 5 business days to fix a non-
compliant job posting after receiving written notice—if corrected, no
penalties apply.
•Capped Damages:Statutory damages range from $100-$500 per
violation (instead of a flat $5,000 per applicant) depending on factors like
willfulness and employer size.
•Fixed Wage Postings Allowed:employers may post a single fixed wage
when no pay range exists.
•No Liability for Scraped Postings: employers are not responsible for
third-party postings or “scraped” job listings beyond their control.
Washington State:
Temporary Rollback & Grace Period
Effective: July 27, 2025 – July 27, 2027

14. Canada

15. Canada
Prince Edward Island
•All employers (not clarified)
•Expected pay or range of expected pay for the role
•Salary history ban
British Columbia
•All employers in BC
•Expected pay or the expected pay range for a job
posting
Newfoundland and LabradorTBD

16. •Who: employers in Ontario
•What:must include expected compensation or salary range in all publicly
advertised job postings (pay range can’t be greater than $50k)
•Includes all wages (salary, bonus, commissions)
•Doesn’t apply is the expected salary exceeds $200k/year
•Salary history ban
•Employers with 100+ employees must prepare “pay transparency
reports” detailing workforce composition and compensation
differenced by gender or other prescribed characteristics
•Since July 1, 2025:employers with 25+ employees will also be required
to provide specific “pre-employment information” to new hires (e.g., starting
wage, hours, pay frequency)
•AI Disclosures: if employer uses AI, must disclose
Ontario
Effective: January 1, 2026

17. Poll 2:What are the main pay
transparency challenges your company
is facing (select all that apply)?
A.Lack of knowledge of legislative requirements
B.Lack of buy in from executive leadership
C.Concerns over cost implications
D.Lack of supporting pay structures and frameworks
E.Manager capability
F.Challenging questions from employees
G.Other (let us know in the Q&A!)

18. Europe

19. EUPTD Key Requirements
Salary ranges must be disclosed in job postings or before
interviews. Candidates can no longer be asked about pay history..
Pay transparency for job seekers:
Employers with 100+ employees must regularly report on their
gender pay gap. Where reporting reveals a gender pay gap of 5% or
more not justified by objective factors, employers must conduct a
joint pay assessment with employee representatives.
Reporting obligations:
Workers have the right to request information on their individual
pay(including benefits) and average pay levels for roles of equal
value, broken down by gender.
Pay transparency for employees:
Employees who suffer pay discrimination can claim compensation.
Burden of proof in disputes will shift to the employer.
Right to compensation and remedies:

20. Status of EU
member states
legislation

21. EU Countries with partial implementation
First country to transpose
law but only applies to
employees in the Fédération
Wallonie-Bruxelles
Belgium
Pay transparency
requirement now in effect
(since August 27, 2025)
Starting salary or pay range
to candidates
Malta
Pay transparency in effect
December 24, 2025
Provide candidates with salary
information and use gender-
neutral language in job ads
Poland
Effective as of June 1, 2025
Workers now able to speak
freely about pay
Czech Republic
1 2 3 4

22. •Not covered by EUPTD
•Gender Pay Gap Reporting Requirements in place since 2017
requiring public, private, and voluntary sector employers with 250 or
more employees, to report annually on their gender pay gap.
•Equality (Race and Disability) Bill remains in draft stage, having been
included in the King's Speech in July 2024. The bill, which will mandate
ethnicity and disability pay gap reporting for larger employers. The
government launched a consultation in March 2025 to gather views on
the new reporting requirements, with implementation not expected
before 2027.
•The UK's call for evidence on pay transparency consultations closed
on June 30, 2025, and the government is currently reviewing the
feedback to decide on potential future policy changes.
United Kingdom

23. How to prepare for the
EU Pay Transparency
Directive now?

24. Consider where this
will impact you
•How many employees do you have in each EU Member State by
entity?
•Note reporting requirement thresholds:
•250 or more must report by June 7, 2027, and every year
thereafter
•150 to 249 workers must report by June 7, 2027, and then
every 3yrs
•100 to 149 workers must report by June 7, 2031, and then
every 3yrs
•Fewer than 100 workers: Member states may dictate lower
pay reporting thresholds.
•Engage stakeholders cross functionally
1

25. 2
Clean up your
compensation data
and policies
•Collect and centralize salaries, bonuses, allowances, and
benefits data
•Build (or fix) your job architecture: clear roles, levels,
grades, and “equal value” groupings
•Define the criteria used to determine pay ranges and career
progression
•Prepare for communication roll out

26. 3
Do a pay equity
analysis, now
•Analyze all pay gaps and ensure they are explainable
•For pay gaps greater than 5%, establish objective
justification for the difference
•Where there is no objective justification for pay disparities,
implement steps to remove those gaps
•EU PTD sets a minimum standard: any pay gap wider
than 5% needs to be explained,. But countries may set
stricter requirements.

27. 4
Audit hiring
practices
Implement a salary history ban at all stages of recruitment.
Audit job posting templates for compliance:
•Are your titles, languages, or requirements accidentally
biased?
•Are your job postings gender neutral
Train in-house talent teams and managers

28. 5
Kill pay
secrecy rules
Audit employment contracts and
policies to ensure that any language
banning employees from talking about
their pay is removed.

29. 6
Upgrade your
systems
Get your HRIS and compensation
management tools ready for reporting,
requests, and audit trails.
Establish process for workers requests for
pay information, making this available to all
on an pro-active basis may be an easier
approach.

30. Payscalesolutions
and data help
organizations
prepare to meet pay
transparency
legislation head on

31. Participate in Payscale's
2026 Compensation Best
Practices Survey to gain
research-backed insights
Ta k e the surv ey toda y
Take the survey today
Link: https://www.research.net/r/CBPR26Page?sf_Contact_Id=%5bsf_Contact_Id_value%5d&sf_Account_Id=%5bsf_Account_Id_value

32. Q&A
Feel free to ask any questions in the
Q&A section of your dashboard!
Would you like a demo of
howPayscale’s
compensation management
solutions can help you in
the wake of increased pay
transparency legislation?
Let us know in the poll
currently open in the
polling tab and the team
will be in touch!