Do Other States’ Pay Transparency Laws Matter?

The following article was provided by Berchem Moses PC. It is reposted here with permission.

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Do Connecticut employers, with no employees in New Jersey, need to comply with New Jersey pay transparency laws?

Maybe.

In today’s interconnected world, businesses are no longer confined by state borders.   

With the rise of remote work, some employers may utilize a workforce scattered across the country or the world. 

Typically, employment laws apply based on the state in which the work is performed. 

However, pay transparency laws often apply across borders, and it is becoming increasingly important for employers to adopt a standardized approach to ensure compliance.

Connecticut Law

In Connecticut, an employer must provide an applicant for employment the “wage range” for the position the applicant is applying for upon request or prior to or at the time an offer of compensation is made, whichever comes first. 

Therefore, any applicant who receives an offer must be told the wage range for the position, even if the applicant did not make a request for the information. 

It is becoming increasingly important for employers to adopt a standardized approach to ensure compliance.

The law applies to current employees as well. 

The employer must provide the wage range for the position at the time of hire, when the employee’s position with the employer changes, or when the employee requests the wage range. 

Connecticut employers also may not ask a prospective employee to disclose wage history.

Pay Transparency Laws

At least 14 states have enacted pay transparency laws. 

Some states require job postings to comply with these laws even if the employer has limited interaction with the state. 

For example, a New Jersey law that took effect June 1, 2025, requires employers with 10 or more employees to comply with the law if they conduct business in New Jersey, employ individuals within New Jersey, or accept applications for employment from within the state. 

These employers must include pay range, benefits, and other forms of compensation in job postings.

To navigate the complexities of pay transparency laws across different states, Connecticut employers can adopt a standardized approach:

1. Disclose wage ranges and benefit information in all internal and external job postings and upon request to applicants and employees.  Ensure that the wage data provided in job postings accurately reflects what you reasonably expect to pay for a role.
2. Disclose pay information for internal job transfers and promotions at an employee’s request.
3. Announce promotion opportunities to every employee the same day the position opens.
4. Do not ask job candidates about their pay history.

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About the author: Rebecca Goldberg is a partner in Berchem Moses PC’s Milford office. She works with human resources professionals and business managers to counsel them through the most challenging workplace situations, from harassment complaints to concerns about an employee’s mental or physical health. Goldberg frequently publishes articles to help employers keep up with new Connecticut and federal laws, providing timely practical guidance.