On October 29, 2025, Massachusetts' Wage Transparency Act, "An Act Relative to Salary Range Transparency", will impose new obligations on employers, requiring them to disclose salary ranges in job postings, as well as provide them to applicants and employees upon request. While the Act was signed into law by Governor Healey in July 2024, the most significant compliance obligations for employers are just around the corner. This article outlines what employers need to know, the deadlines to track, and the steps to take to avoid penalties.
Why Employers Need to Pay Attention
The Wage Transparency Act isn't just about employee rights, it's about employer accountability. Noncompliance can trigger escalating fines, and increased scrutiny from the Attorney General's Office. The law imposes obligations in two main areas: salary range disclosure and workforce demographic reporting.
Salary Range Disclosure
Beginning October 29, 2025, employers in Massachusetts with 25 or more employees must establish and disclose pay ranges in job postings and disclose them to employees. A pay range is defined as "the annual salary range or hourly wage range that the employer reasonably and in good faith expects to pay for such a position at that time." The following disclosures are required:
- Job postings: the annual salary or hourly wage range must be listed in the posting itself.
- Applicants and current employees: Pay ranges must be provided to job applicants, employees seeking a promotion or transfer, and employees beginning a new role.
Moreover, employers are prohibited from retaliating against employees who request this information.
Statutory Penalties for Violations
- First offense = warning
- Second offense = fine of up to $500
- Third offense = fine of up to $1,000
- Fourth and subsequent offenses = subject to more serious penalties as outlined in paragraphs (1) and (2) of subsection (b) of General Laws Chapter 149, Section 27C
It is important to note that until October 29, 2027, employers will be given two business days to correct violations upon receiving a Notice to Cure letter from the Attorney General's office.
Workforce Demographic Data Reporting
The law also imposes annual demographic reporting requirements for larger employers. As of February 1, 2025, private employers with 100 or more employees that already submit EEO (Equal Employment Opportunity) reports to the federal government have been required to also file with the Massachusetts Secretary of the Commonwealth. These reports will be forwarded to the Executive Office of Labor and Workforce Development (EOLWD).
The required reports must include:
- EEO-1 reports - due annually beginning 2025
- EEO-3 reports - due every odd-numbered year beginning 2025
- EEO-4 reports - due every even-numbered year beginning 2026
- EEO-5 reports - due every odd-numbered year beginning 2025
However, this requirement does not create new reporting obligations. Employers already required to file with the EEOC will now submit these reports to the Secretary of the Commonwealth, as well.
Penalties for violations mirror the salary range provisions as follows:
- First offense = warning
- Second offense = fine of up to $500
- Third offense = fine of up to $1000
- Fourth or subsequent offense = subject to more serious penalties as outlined in paragraphs (1) and (2) of subsection (b) of General Laws Chapter 149, Section 27C.
Until covered employers will have two business days to cure reporting defects after receiving a notification from the Attorney General's Office.
Implications for Employers
For businesses, the Wage Transparency Act means taking proactive steps to comply:
- Establish pay ranges for all roles before October 29, 2025
- Update job postings to include salary ranges
- Train HR staff and managers on how to respond to employee requests for pay ranges
- File EEO reports with both the EEOC and the Commonwealth by the appropriate deadlines
- Document compliance efforts to avoid penalties
Employers may choose to disclose salary ranges before the October 2025 deadline, giving them time to adapt and signaling their commitment to fair pay practices.
Looking Ahead
The Massachusetts Wage Transparency Act reflects a broader national trend with states increasingly adopting pay transparency in hopes of closing wage gaps and creating equality in the workplace. As implementation rolls out, the Act will reshape the way employers advertise, manage, and communicate compensation. As the October 29, 2025, deadline quickly approaches, businesses should prioritize taking adequate steps to ensure compliance if they have not already done so.
