Pay Transparency Laws by Country (2026)
Pay transparency rules differ by country and by state or province. This page summarizes what hiring managers need to know for the United States, Canada, the European Union, Ireland, the United Kingdom, Australia and New Zealand.
Pay transparency at a glance
Use this table to see which jurisdictions require a pay range in job postings, which ban pay history questions, and which have pay gap reporting duties. The sections below give the detail for each country.
| Country | Pay in job ads | Pay history questions | Pay gap reporting | Main law |
|---|---|---|---|---|
| United States | Required in 14 states and DC, on request in 2 more | Banned in many states and cities | No federal duty for private employers | State and city laws |
| Canada | Required in BC, Ontario (25+ employees), PEI and New Brunswick | Banned in BC, PEI, New Brunswick and Nova Scotia | BC: 50+ employees from 2026 | Provincial laws |
| European Union | Required in the ad or before interview, once transposed | Banned | 150+ employees from June 2027, 100+ from 2031 | Directive (EU) 2023/970 |
| Ireland | Not required yet | Not banned yet | 50+ employees | Gender Pay Gap Information Act 2021 |
| United Kingdom | Not required (proposal consulted on in 2026) | Not banned | 250+ employees in Great Britain | Equality Act 2010 |
| Australia | Not required | Not banned | WGEA publishes gaps for 100+ employees | Fair Work Act 2009; Workplace Gender Equality Act 2012 |
| New Zealand | Not required | Not banned | Voluntary | Employment Relations Act 2000 (2025 amendment) |
Last checked 4 November 2026. This is general information for employers, not legal advice. Check with employment counsel in each country before you rely on it.
States that require pay in job postings
| State | What the law requires | Since | Applies to | Law |
|---|---|---|---|---|
| California | Pay scale in every job posting. Since January 2026 the scale must be a good-faith estimate of the range the employer expects to pay at hire. | January 2023 | 15 or more employees | SB 1162; SB 642 (Labor Code 432.3) |
| Colorado | Pay range and a general description of benefits in every posting, including remote jobs that could be done in Colorado. | January 2021 | Any employer with staff in Colorado | Equal Pay for Equal Work Act (SB 19-085) |
| Connecticut | Wage or a good-faith wage range and a general description of benefits in every internal and external posting. | October 1, 2026 | All employers | Public Act 26-12 (HB 5003) |
| Washington DC | Minimum and maximum pay in every posting, and healthcare benefits disclosed before the first interview. | June 30, 2024 | All employers | Wage Transparency Omnibus Amendment Act of 2023 |
| Hawaii | Hourly rate or salary range in job postings. | January 2024 | 50 or more employees | Act 203 (SB 1057, 2023) |
| Illinois | Pay scale and benefits in postings, or a link to them, for jobs done at least partly in Illinois or reporting to an Illinois supervisor or site. | January 2025 | 15 or more employees | HB 3129 (Equal Pay Act, 820 ILCS 112) |
| Maine | Pay range in postings, or a statement that pay is commission only. Current employees can ask for the range of their own role. | July 29, 2026 | 10 or more employees | LD 54 (26 MRSA 622-A) |
| Maryland | Wage range and a general description of benefits and other compensation in postings. | October 2024 | All employers | SB 525 (2024) |
| Massachusetts | Pay range in postings. Benefits do not have to be listed. | October 29, 2025 | 25 or more employees in Massachusetts | H.4890 (2024) |
| Minnesota | Starting pay range, which cannot be open-ended, and a general description of benefits in postings. | January 2025 | 30 or more employees in Minnesota | Minn. Stat. 181.173 |
| New Jersey | Pay range and a general description of benefits in every posting. | June 1, 2025 | 10 or more employees over 20 calendar weeks | P.L. 2024, c.91 (S2310) |
| New York | Pay range in postings for jobs done at least partly in New York or reporting to a New York supervisor. | September 17, 2023 | 4 or more employees | Labor Law 194-b |
| Vermont | Good-faith pay range in postings, including remote jobs that mainly serve a Vermont office. | July 2025 | 5 or more employees, at least one in Vermont | Act 155 (H.704) |
| Virginia | Good-faith wage or salary range in all public and internal postings. Employers may not ask about salary history. | July 1, 2026 | All employers | HB 636 and SB 215 (2026) |
| Washington | Wage scale or a fixed wage and a general description of benefits in postings. Since July 2025 employers get five business days to fix a missing range after written notice. | January 2023 | 15 or more employees | RCW 49.58.110; SSB 5408 |
States that require pay on request
| State | What the law requires | Since | Applies to | Law |
|---|---|---|---|---|
| Nevada | Wage range given to any applicant who has had an interview. Employers may not ask about salary history. | October 2021 | All employers | SB 293 (NRS 613.133) |
| Rhode Island | Wage range given on request, at hire and when an employee moves to a new role. No posting requirement. | January 2023 | All employers | R.I. Gen. Laws 28-6-18 |
US laws signed and starting soon
| Where | What the law requires | Starts | Applies to | Law |
|---|---|---|---|---|
| Delaware | Pay or pay range and a general description of benefits in postings. | September 26, 2027 | 26 or more employees | House Substitute 2 for HB 105 (signed September 2025) |
| Columbus, Ohio | Reasonable salary range in external postings for jobs done in Columbus. | January 1, 2027 | 15 or more employees in the city | Ordinance 2898-2025 |
US city laws
| City | What the law requires | Since | Applies to | Law |
|---|---|---|---|---|
| New York City | Minimum and maximum pay in postings. | November 2022 | 4 or more employees | Local Law 32 of 2022 |
| Ithaca, New York | Minimum and maximum pay in postings for jobs based in Ithaca. | September 2022 | 4 or more employees | City human rights ordinance |
| Jersey City, New Jersey | Minimum and maximum pay and benefits in postings. | April 2022 | 5 or more employees | Ordinance 22-026, amended by 22-045 |
| Cleveland, Ohio | Salary range in postings, with benefits counted as part of salary. Employers may not ask about salary history. | October 27, 2025 | 15 or more employees in the city | Ordinance 104-2025 |
Westchester County, New York had its own posting rule until the statewide law replaced it in September 2023.
States with no statewide posting law
Alabama, Alaska, Arizona, Arkansas, Florida, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Michigan, Mississippi, Missouri, Montana, Nebraska, New Hampshire, New Mexico, North Carolina, North Dakota, Ohio (city rules only), Oklahoma, Oregon, Pennsylvania, South Carolina, South Dakota, Tennessee, Texas, Utah, West Virginia, Wisconsin, Wyoming.
A state without a posting law can still ban pay history questions or protect pay discussions, so check the state rules for the role.
Canada: pay transparency laws by province
Canada has no federal posting rule. British Columbia requires a pay range in public job ads and bans pay history questions. Since 1 January 2026 Ontario has required employers with 25 or more employees to state pay or a range no wider than $50,000 in public postings. The same rules add AI disclosure, vacancy status and a 45-day decision notice for interviewed candidates. Prince Edward Island requires a pay range in postings and bans pay history questions. New Brunswick's Pay Transparency Act covers public and internal postings and bans pay history questions.
| Province | What the law requires | Since | Applies to | Law |
|---|---|---|---|---|
| British Columbia | Expected pay or pay range in every publicly advertised job. No pay history questions. Employees can discuss pay without retaliation. Annual pay transparency reports, published by 1 November. | 1 November 2023 (reports for 50+ employees from 2026) | All employers | Pay Transparency Act, SBC 2023 c.18 |
| Ontario | Expected pay or a range no wider than $50,000 in public postings (not needed above $200,000). Disclose AI use in screening, say whether the vacancy exists, no Canadian experience requirement, and tell interviewed candidates within 45 days whether a decision has been made. | 1 January 2026 | 25 or more employees | Employment Standards Act, 2000, ss.8.1 to 8.6; O. Reg. 476/24 |
| Prince Edward Island | Expected pay or range in public postings. No pay history questions, though employers can ask about pay expectations. | 1 June 2022 | All employers | Employment Standards Act, ss.5.8 to 5.10 |
| New Brunswick | Pay or range in public and internal postings. No pay history questions. Pay reporting for 50+ employees to follow once proclaimed. | 12 June 2026 | All employers | Pay Transparency Act (Bill 24, 2026) |
| Nova Scotia | No posting rule. Pay history questions banned and pay discussions protected. | In force | All employers | Labour Standards Code |
| Newfoundland and Labrador | Posting and pay history rules passed but not yet in force. | Not proclaimed | Not yet | Pay Equity and Pay Transparency Act, SNL 2022 |
| Federal | No posting rule. Pay equity plans for federally regulated employers, and pay gap data in employment equity reports. | 31 August 2021 | Federally regulated employers (10+ for pay equity, 100+ for employment equity reports) | Pay Equity Act; Employment Equity Act |
European Union: Pay Transparency Directive
The EU Pay Transparency Directive (EU) 2023/970 had a transposition deadline of 7 June 2026. By early November 2026 only Greece, Italy, Lithuania, Malta and Slovakia had fully transposed it. Where it applies, candidates must receive pay or a range in the ad or before interview. Employers may not ask about pay history. Pay secrecy clauses are banned. Workers can request average pay by sex for equal-value work. Pay gap reports begin in June 2027 for employers with 150 or more employees and from 2031 for 100 to 149 employees.
| Member state | Status | Notes |
|---|---|---|
| Austria | Not transposed | Internal draft only. Existing income reports for employers with 150+ staff still apply. |
| Belgium | Not transposed | No federal bill for the private sector. |
| Bulgaria | Draft or bill published | Bill sent to the National Assembly in September 2026, target 1 January 2027. |
| Croatia | Not transposed | No draft published. |
| Cyprus | Draft or bill published | Revised draft published January 2026. |
| Czechia | Draft or bill published | Pay secrecy ban in force since 2025. Labour Code amendment passed first reading October 2026. |
| Denmark | Draft or bill published | Bill amending the Equal Pay Act before the Folketing, target 1 January 2027. |
| Estonia | Partly transposed | Recruitment and pay secrecy rules in force 13 July 2026. Reporting not yet transposed. |
| Finland | Draft or bill published | Government proposal in Parliament, target 1 January 2027. |
| France | Draft or bill published | Bill before Parliament since September 2026. |
| Germany | Not transposed | No published draft. |
| Greece | Transposed | Law 5316/2026, most duties apply from 1 November 2026. |
| Hungary | Not transposed | No bill introduced. |
| Ireland | Not transposed | Phased approach planned, no bill text yet. See below. |
| Italy | Transposed | Legislative Decree 96/2026, in force 7 June 2026. |
| Latvia | Draft or bill published | Draft law at Cabinet stage, target 1 January 2027. |
| Lithuania | Transposed | Labour Code amendments from 7 June 2026. Pay reporting from 1 January 2027. |
| Luxembourg | Not transposed | Nothing tabled. |
| Malta | Transposed | Legal Notices 112/2025 and 173/2026, fully in force 5 June 2026. |
| Netherlands | Draft or bill published | Bill 36949 in Parliament, government target 1 January 2027. |
| Poland | Partly transposed | Pay range, pay history ban and neutral ads in force 24 December 2025. Rest in draft. |
| Portugal | Draft or bill published | Draft law published August 2026. |
| Romania | Draft or bill published | Rejected by the Senate October 2026, now before the Chamber of Deputies. |
| Slovakia | Transposed | Equal Pay Act in force 7 June 2026. |
| Slovenia | Not transposed | Internal draft only. |
| Spain | Draft or bill published | Draft published August 2026. Existing pay register and audit rules apply. |
| Sweden | Not transposed | Government will not submit a bill and wants the directive renegotiated. |
Status as of early November 2026, from law firm and adviser trackers. There is no official Commission table, and bills can move quickly, so check the member state before you post.
Ireland
Ireland missed the 7 June 2026 deadline to transpose the EU Pay Transparency Directive and plans to bring it in on a phased basis. No law yet requires a salary in job ads, and no bill text has been published. Gender pay gap reporting already applies to employers with 50 or more employees, with a snapshot date in June and publication by November. Employers who start putting ranges in Irish ads now will have less to change when the rules arrive.
- Pay in job ads: not required yet. Pre-employment pay information and a pay history ban are planned in the Equality (Miscellaneous Provisions) Bill or the Pay Transparency Bill.
- Gender pay gap reporting: employers with 50 or more employees, snapshot date in June, report published within five months (Gender Pay Gap Information Act 2021, 2025 Regulations).
- Enforcement: IHREC or an employee can apply to the WRC or Circuit Court for an order to comply.
United Kingdom
The United Kingdom has no law requiring pay in job adverts and no salary history ban. A government consultation closed on 27 October 2026 proposed requiring pay information in job adverts or before interview. Gender pay gap reporting applies to employers with 250 or more employees in Great Britain. Equality Act 2010 s.77 protects workers who discuss pay. Northern Ireland has no gender pay gap reporting duty yet. Gender pay gap action plans become mandatory in Great Britain from 2027 for employers with 250 or more employees.
- Pay in job ads: not required. The Equal pay and pay discrimination consultation (closed 27 October 2026) proposes pay information in adverts, or in writing before interview where there is no advert.
- Pay history: no ban, and none proposed.
- Discussing pay: protected in Great Britain where the aim is to find out about pay discrimination (Equality Act 2010, s.77).
- Gender pay gap reporting: Great Britain employers with 250 or more employees, snapshot 5 April (31 March in the public sector), published within 12 months. Action plans become mandatory from 2027 under the Employment Rights Act 2025.
- Northern Ireland: no gender pay gap reporting duty yet.
- Scotland: listed public authorities with 20 or more employees publish gender pay gap information.
Australia
Australia has no requirement to put pay in job ads. Pay secrecy clauses have had no effect since 7 December 2022. Including them in new contracts has been a civil penalty breach under the Fair Work Act since 7 June 2023. WGEA publishes gender pay gaps of private employers with 100 or more employees each year. Employers with 500 or more employees must set gender equality targets.
- Pay in job ads: not required by federal or state law.
- Pay secrecy: employees can share or keep private their pay and ask others about theirs. Pay secrecy terms have had no effect since 7 December 2022, and it has been a civil penalty breach to put one in a new contract since 7 June 2023 (Fair Work Act 2009, ss.333B to 333D).
- Gender pay gaps: WGEA publishes the gap of every private employer with 100 or more employees each year, most recently on 3 March 2026.
- Targets: employers with 500 or more employees must choose gender equality targets and report progress (Setting Gender Equality Targets Act 2025).
New Zealand
New Zealand has no rule requiring pay in job ads and no gender pay gap reporting duty. Since 27 August 2025 employees have been free to disclose their pay, and a pay secrecy clause in an employment agreement cannot be enforced against them. Treating an employee badly for sharing their pay can ground a personal grievance. Reporting on pay gaps remains voluntary.
- Pay in job ads: not required.
- Pay secrecy: employees may disclose their pay from 27 August 2025, and adverse treatment for doing so is a personal grievance (Employment Relations (Employee Remuneration Disclosure) Amendment Act 2025).
- Gender pay gap reporting: voluntary.
How to write one job ad that works in several countries
1. Include a pay range in the ad
Put a salary range in the posting. Fourteen US states plus Washington DC require one, and several Canadian provinces do too. The EU directive allows the range to be given before the interview, though putting it in the ad is simpler. Base the range on current market data for the role location. In Ontario the range can be no more than $50,000 wide.
2. Check where remote workers sit
A remote role can fall under the rules of the place where the worker lives, and some US states also cover roles that report to a manager or office in the state. If a remote ad is open to candidates in several states or provinces, follow the strictest rule that could apply.
3. Do not ask about pay history
Pay history questions are banned under the EU directive and in British Columbia, Prince Edward Island, New Brunswick and Nova Scotia. Many US states and cities ban them too, including California, New York, Massachusetts, Virginia and Nevada. Ask about pay expectations instead and point to your posted range.
4. Disclose AI use and vacancy status for Ontario
Since 1 January 2026 Ontario has required employers with 25 or more employees to say whether a posting is for an existing vacancy and to disclose AI use in screening. Add both statements to any ad that could be filled in Ontario, and reply to interviewed candidates within 45 days.
5. Check city rules before posting
City rules in New York City, Ithaca, Jersey City and Cleveland apply on top of state rules, and Columbus joins them on 1 January 2027. If the role sits in one of these cities, check the city wording before you publish.
How Aristo Search handles pay ranges
Aristo Search is a recruitment agency, part of Aristo Sourcing LLC. We hire for clients in the United States, Canada, the United Kingdom, Ireland, Australia and New Zealand. For every role we build a pay range from current market data for the location of the role. We check the posting rules for where the role is based and where a remote worker sits. We keep a note of how each range was set. That note records the data source and the applicable local rules.
See our cross-border hiring services and global recruitment services.
More hiring guides and tools
Sources
- EU directive: eur-lex.europa.eu
- EU, no delay: iuslaboris.com
- EU member states: iuslaboris.com
- EU member states: global.lockton.com
- Ireland: algoodbody.com
- United Kingdom: lewissilkin.com
- Northern Ireland: lewissilkin.com
- Australia: fairwork.gov.au
- Australia: wgea.gov.au
- New Zealand: legislation.govt.nz
- British Columbia: gov.bc.ca
- Ontario: osler.com
- Prince Edward Island: stewartmckelvey.com
- New Brunswick: legnb.ca
- Nova Scotia, Newfoundland and Labrador: mcinnescooper.com
- California: morganlewis.com
- Connecticut: seyfarth.com
- Maine: littler.com
- Massachusetts: jacksonlewis.com
- New York: ebglaw.com
- Virginia: ogletree.com
- Washington: morganlewis.com
- Rhode Island: taxnews.ey.com
- Delaware: morganlewis.com
- Columbus, Ohio: hahnlaw.com
- Ithaca, New York: littler.com
- Jersey City, New Jersey: jerseycitynj.gov
- Cleveland, Ohio: hahnlaw.com
Questions employers ask
Which countries require salary in job ads?
Fourteen US states plus Washington DC require a pay range in job postings, and Nevada and Rhode Island require it on request. In Canada, British Columbia, Ontario, Prince Edward Island and New Brunswick require pay or a range in postings. The EU directive requires pay information in the ad or before interview once each member state transposes it. Ireland, the UK, Australia and New Zealand do not require pay in ads yet.
Does the EU Pay Transparency Directive apply to non-EU companies hiring in the EU?
The EU directive applies to jobs in EU member states. It does not depend on where the employer is based. Non-EU companies hiring workers in the EU must follow the rules once the member state has transposed the directive. As of early November 2026 only Greece, Italy, Lithuania, Malta and Slovakia had fully transposed it.
Do remote roles count for pay transparency rules?
Often, yes. Several US states cover remote roles that could be done in the state or that report to a manager there, so a fully remote US ad usually needs a range. In Canada check the province where the worker will be. For EU roles follow the rules of the member state where the work is done.
Can I ask candidates about their current salary?
Not in the EU once the directive is in force locally, and not in British Columbia, Prince Edward Island, New Brunswick or Nova Scotia. The US has no federal ban, though many states and cities have one, including California, New York, Massachusetts, Virginia and Nevada. The UK, Australia and New Zealand have no ban. The safest habit is to ask about pay expectations instead.
What is happening in the UK?
The UK has no law requiring pay in job adverts and no salary history ban. A government consultation closed on 27 October 2026 proposed requiring pay information in job adverts or before interview. Gender pay gap reporting applies to employers with 250 or more employees in Great Britain. From 2027 gender pay gap action plans become mandatory for those employers.
What are the pay gap reporting thresholds?
Ireland requires gender pay gap reporting for employers with 50 or more employees. Great Britain requires it for 250 or more employees. Australia publishes gender pay gaps of private employers with 100 or more employees each year. The EU will require pay gap reports from June 2027 for employers with 150 or more employees, yearly at 250 or more, and from 2031 for 100 to 149 employees.
What should I include in a job ad to cover several countries?
Include a pay range for the role location, avoid any question about past pay, and say how benefits work where the law asks for it. If the role could be filled in Ontario, state whether there is an existing vacancy and whether AI is used in screening. For US roles in New York City, Ithaca, Jersey City, Cleveland or Columbus, check the city rules as well.
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