Massachusetts Pay Transparency Law: What Employers Need to Know Before October 2025
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Massachusetts Pay Transparency Law: What Employers Need to Know Before October 2025
In a move that underscores the growing momentum behind equitable workplace practices, Massachusetts has passed a new pay transparency law. For employers, this is more than a compliance checkbox; it’s a call to reexamine compensation strategies and foster a culture of openness and trust.
There are two key requirements, eligibility thresholds and effective dates employers need to understand so that they can determine what requirements apply to them.
What’s Changing?
The new law, officially titled An Act Relative to Salary Range Transparency but most commonly referred to as the Massachusetts Pay Transparency Law or Act, introduces two major requirements for employers:
Pay Range Disclosures – Effective October 29, 2025
Employers with 25 or more employees must disclose pay ranges in three scenarios:
- In all job postings
- When an employee applies for a promotion or transfer
- provide clear notices to affected employees and applicants
- Upon request by a current employee for their own position
I should note that Massachusetts law defines “pay range” as the salary or hourly wage an employer reasonably and in good faith expects to pay for a position at the time of posting. Notably, the Massachusetts law does not require employers to disclose bonuses, commissions, or benefits. However, other state transparency laws may come into effect when hiring for remote positions that require that employers disclose additional information.
Pay Data Reporting: Beginning February 2025
Employers with 100 or more employees who already submit federal EEO wage data must now also submit those reports to the Commonwealth. This applies annually or biennially, depending on the organization type.
Note: The law does not introduce any new data collection requirements – employers only need to file a copy of the same report they filed with the EEOC with the Commonwealth based on the following schedule:
| Employers Who File: | Must file EEO Report with the Secretary | Due By | Starting in Year |
|---|---|---|---|
| EEO-1 | Annually | February 1 | 2025 |
| EEO-3 | Odd Numbered Years | February 1 | 2025 |
| EEO-4 | Even Numbered Years | February 1 | 2026 |
| EEO-5 | Odd Numbered Years | February 1 | 2025 |
Why It Matters
Pay transparency laws are gaining traction nationwide and for good reason. They aim to close persistent wage gaps across gender and racial lines, promote fairness, and build employee trust. Massachusetts’ law is part of a broader trend that’s reshaping how organizations approach compensation.
But compliance isn’t just about posting salary ranges. It requires a thoughtful, proactive approach to compensation strategy. Employers must ensure internal equity, prepare managers to handle pay conversations, and develop consistent processes for job postings and employee communications.
Enforcement and Penalties
The good news is, the law includes a 2-year grace period. Until October 29, 2027, if an employer receives a notice from the Attorney General’s Office, they will have two (2) business days to correct violations. After that, penalties escalate quickly—from a warning to fines of up to $25,000 per offense for repeat violations.
Employees are also protected from retaliation for exercising their rights under the law. If they believe their rights have been violated, they can file a complaint with the Attorney General’s Office.
How to Prepare
Now is the time to act. Employers should:
- Determine or confirm pay philosophy
- Market price jobs by consulting market data to assess current rates to market
- Create pay ranges based on market results/comparable jobs
- Conduct an internal pay audit to ensure employees are paid equitably
- Consider “comparable jobs” and take necessary steps to ensure pay equity among your existing workforce - before information becomes public
- Draft posting language to include with pay range information, including any necessary disclaimers regarding the posted pay range, i.e., the advertised pay range is not a promise of a particular wage
- Develop a process to consistently post the required information in job postings
- Adopt processes that ensure the ability to know where employees are located, especially with the prominence of remote work
- Develop strategies for communicating with employees and applicants about pay ranges
- Provide training to hiring managers on how to handle pay inquiries
- For employers with 100+ employees, ensure the reporting deadline was/is met
Final Thoughts
Massachusetts’ new law is a significant step toward greater pay equity and transparency. While it introduces new compliance requirements, it also presents an opportunity for organizations to lead with integrity and build stronger, more equitable workplaces.
Need help navigating these changes? Our HR advisors can offer strategic guidance and resources such as a customized Compensation Planning Toolkit to help you prepare for the future.