<table>
  <tr>
    <th>Title</th>
    <th>Effective Date</th>
    <th>Law Requirements</th>
    <th>Enforcement / Penalties</th>
  </tr>

  <tr>
    <td>California</td>
    <td>1/1/2023</td>
    <td>
      <p>Salary ranges and hourly wage ranges must be put on all CA job listings (Please note: Bonuses, equity, or other types of compensation are not required to be disclosed). The law requires that an employer with 15 or more employees (even if only 1 employee in CA) must include the pay scale for a position in any job posting, whether the posting is internal or external. If such an employer engages a third party to announce, post, publish, or otherwise make known a job posting, the employer must provide the pay scale to the third party, and the third party must include the pay scale in the job posting. Employers must maintain records of job titles and wage rate history for all employees for duration of employment plus 3 years. These records must be available for inspection by the Labor Commissioner. Employers required to submit a pay data report to the Civil Rights Department (formerly, the Department of Fair Housing and Employment) covering the prior calendar year. They must include the median and mean hourly rate within each job category, each combination of race, ethnicity, and sex on an annual basis. The deadline is the second Wednesday of May of each year. Employers with multiple establishments will have to submit a report for each establishment. Employers must provide an employee the pay scale for which they are currently employed. Beginning 2023, employers with 100 or more employees hired through labor contractors must submit a separate pay data report to the CDR covering workers hired through labor contractors for the prior calendar year. The employer shall report the ownership of the names of all the labor contractors used to supply employees. Labor contractors to supply all necessary pay data to the private employer so the employer can file the report.</p>
    </td>
    <td>
      <ul>
        <li>The bill will create a rebuttable presumption in favor of an employee's claim if an employer fails to keep records in violation of these provisions.</li>
        <li>This bill will permit a court to impose a civil penalty not to exceed one hundred dollars ($100) per employee upon any employer who fails to file the required report and not to exceed two hundred dollars ($200) per employee upon any employer for a subsequent failure to file the required report.</li>
        <li>The bill would create a rebuttable presumption in favor of an employee's claim if an employer fails to keep records in violation of these provisions.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Colorado</td>
    <td>1/1/2021</td>
    <td>
      <p>Colorado's Equal Pay Work Act requires employers to list the pay range and benefits for every job opening. Even if you have only employees in Colorado, you're required to post pay for any remote job that could potentially be performed in the state. Employers must also notify current employees of all promotion opportunities and keep records of job descriptions and wages. Only if it based on contributions made by the Employee. The contributions must be part of the employee's existing job and not within a position with a current or anticipated vacancy. Postings regarding career progressions are only available to eligible employees. An eligible employee is one in a position that, when the requirements in the notice are satisfied, would move from their position to another position listed in the notice as "career progression." Post-selection notice requirements to other employees are only required when they collaborate or communicate about their work at least monthly or have a reporting relationship. Employers may post individual selections or in groups so long as they post no later than thirty days after their selection. AINT HIRES (Acting, Interim, Temporary) no posting is required for an AINT hire so long as the AINT hire is not expected to be permanent and the same position was not held by another AINT hire within the past seven months that was not posted. Employers must maintain records of job descriptions and wage rate history for each employee for two years after employment ends. Postings for jobs and promotions must include the hourly rate or salary compensation (or range); a general description of any bonuses, commissions, or other forms of compensation; and a general description of all employee benefits, including health care, retirement, paid days off, and other benefits that must be provided for federal tax purposes. In electronic postings, employers do not need to include this information if it is hyperlinked or accessible via URL provided within the electronic posting. Records must be kept of employees’ job descriptions and compensation for the duration of the employee’s employment plus two years thereafter. Application deadlines must have a posted anticipated close date.</p>
    </td>
    <td>
      <ul>
        <li>Failing to maintain records of job descriptions and wage rate histories creates a rebuttable presumption that the records not maintained contained information favorable to an employee’s claim.</li>
        <li>In addition to other remedies, liquidated damages are awarded unless the employer can show its violation was in good faith. One way an employer may do so is by having conducted a “thorough and comprehensive pay audit” with the “specific goal of identifying and remedying unlawful pay disparities” within two years before the lawsuit was filed.</li>
        <li>Failing to list one promotional opportunity is considered one violation; failing to disclose one job opening is considered one violation regardless of the number of postings that list the job opening. Fines of between $500 and $10,000 may be levied per violation.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Colorado</td>
    <td>1/1/2024</td>
    <td>
      <p>This Amendment requires that an employer shall make reasonable efforts to announce, post, or otherwise make known each job opportunity to all employees on the same calendar day and prior to the date on which the employer makes a selection decision; except that, if an employer is only physically located outside of Colorado and has fewer than fifteen employees working in Colorado, all of whom work only remotely, then, through July 1, 2029, the employer is only required to provide notice of remote job opportunities. The Department of Labor and Employment shall promulgate rules for temporary, interim, or acting job opportunities that necessitate immediate hire. Employers will be required to disclose the hourly or salary compensation or the range of the hourly or salary compensation; a general description of the benefits and other compensation applicable to the job opportunity; and the date the application window is anticipated to close. The employer also must provide transparency regarding the candidate selected for a job opportunity to the employees with whom the selected candidate will regularly be working. This includes the name of the candidate selected for the job opportunity; the selected candidate’s former job title if selected while already employed by the employer; the selected candidate's new job title; and information on how employees may demonstrate interest in similar job opportunities in the future, including identifying individuals or departments to whom the employees can express interest in similar job opportunities.</p>
    </td>
    <td></td>
  </tr>

  <tr>
    <td>Connecticut</td>
    <td>10/1/2021</td>
    <td>
      <p>Employers are required to provide a salary range for all extended offers, or before then, if the candidate asks for it. They must also disclose wage ranges for vacant positions to current employees. The department of labor defines wage range as the "range of wages an employer anticipates relying on when setting wages for a position, and may include reference to any applicable pay scale, previously determined range of wages for the position, actual range of wages for those employees currently holding comparable positions or the employers' budgeted amount for the position."</p>
    </td>
    <td>
      <ul>
        <li>Enforcement; no action shall be brought for any violation except within two (2) years after such violation.</li>
        <li>Violation; violators will be liable for compensatory damages, attorney's fees and costs, punitive damages and such legal and equitable relief as the court deems just and proper.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>District of Columbia</td>
    <td>6/30/2024</td>
    <td>
      <p>Employers with 25 or more workers are to include salary ranges in job postings and disclose healthcare benefits before the first interview. It also prohibits employers from seeking wage history from applicants. Employers must post notice in a “conspicuous” place informing employees of their rights under the Wage Transparency Omnibus Amendment Act of 2023.</p>
    </td>
    <td>
      <ul>
        <li>Fines range between $1,000 and $20,000 per violation.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Hawaii</td>
    <td>1/1/2024</td>
    <td>
      <p>Employers with over 50 or more employees will be required to disclose in job listings an hourly rate or salary range that reasonably reflects the actual expected compensation for the role. The law does not require employers to disclose pay information in job listings for positions that are internal transfers or promotions within the company. the law does not specify whether the fifty employee threshold refers to employees within Hawaii or to a company's total employee count. To be conservative, TCW will proceed as if this applies to company's total employee count - unless clarification comes out to the contrary.</p>
    </td>
    <td>
      <ul>
        <li>While the bill does not contain separate provisions regarding enforcement and penalties, Hawaii generally allows individuals claiming to be aggrieved by an alleged unlawful discriminatory practice to file a complaint with the Hawaii Civil Rights Commission.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Illinois</td>
    <td>1/1/2025</td>
    <td>
      <p>Employers with 15 or more employees to include pay ranges and benefits in job postings. Employers are required to notify current employees of all opportunities for promotion within 14 days of making an external job posting for the position. Applies to both positions physically performed in IL or will be performed outside IL but the employee reports a supervisor, office, or other work site in IL.</p>
    </td>
    <td>
      <ul>
        <li>Aggrieved parties can file a complaint with the IL department of labor.</li>
        <li>All complaints must be filed within one year from the date of the violation.</li>
        <li>If determined a violation has occurred the department may assess fines up to $500 for the first offense, $2,500 for a second offense, and $10,000 for a third offense.</li>
        <li>Before fines are levied, employers will be given notice and a cure period (14 days for first offense 7 days for second offense).</li>
        <li>Employers will incur automatic penalties without a cure period for five years following a third offense.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Massachusetts</td>
    <td>1/1/2025</td>
    <td>
      <p>Employers are required to disclose the pay range for employment positions. This not only applies to new positions but also for current employees that are offered promotions or transfers to new positions with different responsibilities. The law applies to employers with 25 or more employees in Massachusetts and employers with out-of-state headquarters but with 25 or more employees in Massachusetts. The requirement also extends to agents of employers, such as recruiters and placement agencies.</p>
    </td>
    <td>
      <ul>
        <li>First violations are is a warning; second offense is not more than $500; third offense not more than $1,000; Any subsequent offenses will be $7,500 to $25,000 per violation.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Maryland</td>
    <td>10/1/2024</td>
    <td>
      <p>Maryland employers are required to disclose wage ranges and a general description of benefits and any other compensation offered on any public or internal posting for a "position for work that will be physically performed, at least in part, in Maryland. Employers must also also retain a copy of the posting for 3 years after the position was filled or posted (if never filled).</p>
    </td>
    <td>
      <ul>
        <li>Penalties; First violation, issue a letter to the employer compelling compliance;</li>
        <li>Second violation, assess a civil penalty of up to $300 for each applicant; each subsequent violation a civil penalty of up to $600 for each applicant for employment within 3 years after a previous determination that a violation had occurred.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Minnesota</td>
    <td>1/1/2025</td>
    <td>
      <p>Employers with 30 or more workers in Minnesota must include a salary range and a general description of benefits in all job postings. This applies to any solicitation, electronic or printed, that includes qualifications for applicants.</p>
    </td>
    <td>
      <ul>
        <li>Not specified</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Nevada</td>
    <td>10/1/2021</td>
    <td>
      <p>Employers are also required to provide applicants with the wage or salary for the position once an applicant has interviewed for a position. This includes employees that have applied for promotions or to transfer within the company.</p>
    </td>
    <td>
      <ul>
        <li>Penalties; In addition to any other remedy or penalty, the Labor Commissioner may impose an administrative penalty of not more than $5,000 for each violation.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>New Jersey</td>
    <td>6/1/2025</td>
    <td>
      <p>Employers that do business in New Jersey, have workers in New Jersey, or take applications within the state of New Jersey and have at least 10 workers over 20 calendar weeks are required to disclose salary or wage ranges and benefits information in job postings for both new hires and internal transfers. Employers must also make reasonable efforts to inform current employees about promotional opportunities.</p>
    </td>
    <td>
      <ul>
        <li>Penalties for non-compliance include a $300 fine for the first violation and a $600 fine for each subsequent violation.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Rhode Island</td>
    <td>1/1/2023</td>
    <td>
      <p>Employers must provide candidates with a pay range if the interviewee requests it. This is applicable to transfers, promotions, and if the employee requests during any time during their employment. Employer must disclose the pay range for a role before discussing compensation with the candidate.</p>
    </td>
    <td>
      <ul>
        <li>Penalties; In addition to any other relief to which any aggrieved party may be entitled to, the employer may be liable for a civil penalty to be paid to the department of labor and training.</li>
        <li>Up to $1,000 for first violation;</li>
        <li>Up to $2,500 where the employer has had one violation within the 5 years prior to the complaint or action being filed; or</li>
        <li>Up to $5,000 for a violation where the employer has had two or more violations within the 7 years prior to the complaint or action being filed.</li>
        <li>No civil penalties shall be assessed from January 1, 2023 to December 31, 2024.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Washington</td>
    <td>1/1/2023</td>
    <td>
      <p>Employers must disclose the pay scale and salary on all job postings. This also includes a description of benefits and other compensation information related to the position.</p>
    </td>
    <td>
      <ul>
        <li>Penalties: First violation, the civil penalty may not exceed $500.</li>
        <li>For a repeat violation, the civil penalty may not exceed $1,000 or ten percent of the damages, whichever is greater. Any wages and interest owed must be calculated from four years from the last violation before the compliant.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Toledo, Ohio</td>
    <td>6/25/2020</td>
    <td>
      <p>Upon reasonable request, employer must provide a "pay scale" for the position sought by an applicant of employment, but must only do so after the employer has made a conditional offer of employment to the applicant.</p>
    </td>
    <td>
      <ul>
        <li>Penalties; The applicant shall have a private cause of action for compensatory damages, reasonable attorney's fees, the costs of action, and such legal and equitable relief as the court deems just and proper.</li>
        <li>An action for violation shall be commenced within 2 years after the cause of action accrued.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Cincinnati, Ohio</td>
    <td>3/13/2020</td>
    <td>
      <p>Employer must provide a pay range of a job after they have made a conditional offer of employment if requested by the applicant.</p>
    </td>
    <td>
      <ul>
        <li>Penalties; The applicant shall have a private cause of action for compensatory damages, reasonable attorney's fees, the costs of action, and such legal and equitable relief as the court deems just and proper.</li>
        <li>An action for violation shall be commenced within 2 years after the cause of action accrued.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Cleveland, Ohio</td>
    <td>10/27/2025</td>
    <td>
      <p>Employers with 15 or more workers must include pay ranges in job postings located within the city, covering all applicable compensation and benefits. Ranges must reflect the minimum and maximum pay for the position in both internal and external postings. Employers are prohibited from asking caniddates about their pay history. They must maintain records of pay ranges, provide clear job descriptions, and ensure that pay equity across gender, race, and other protected categories.</p>
    </td>
    <td>
      <ul>
        <li>The Fair Employment Wage Board (FEWB) may assess civil penalties: up to $1,000 for first-time violations and up to $5,000 for repeated offenses within the past five years.</li>
        <li>For first-time violations, the FEWB will prioritize resolution through education and guidance.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>New York State</td>
    <td>9/17/2023</td>
    <td>
      <p>Companies that advertise a job, promotion, or transfer opportunity must include: (1) the compensation or a range of compensation for such job, promotion, or transfer opportunity; and (2) the job description for such job, promotion, or transfer opportunity, if such description exist. “Range of compensation” is defined as the minimum and maximum annual salary or hourly range the employer in good faith believes to be accurate at the time of the posting.</p>
    </td>
    <td>
      <ul>
        <li>Penalties:</li>
        <li>$1,000 for the first violation</li>
        <li>$2,000 for the second violation</li>
        <li>$3,000 for the third violation and beyond</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>New York, NY</td>
    <td>11/1/2022</td>
    <td>
      <p>Employers are required to include a pay range on all new job postings. Additionally, Employers must provide a salary range for any promotions or transfers within the company. The law applies to positions within the city and those that are remote</p>
    </td>
    <td>
      <ul>
        <li>Penalties; No civil penalty will be assessed for a first complaint alleging a violation of the salary transparency provision, if the employer shows they have fixed the violation within 30 days of receiving the Commission's notice of the violation.</li>
        <li>Covered employers may have to pay civil penalties of up to $250,000 for a uncured first violation as well as for any subsequent violations.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Ithaca, NY</td>
    <td>9/1/2022</td>
    <td>
      <p>Employers must include the range of pay including both the minimum and maximum pay for the position. This is for all new job positions, promotions, and transfers. The law applies to positions within the city.</p>
    </td>
    <td>
      <ul>
        <li>While the bill does not contain separate provisions regarding enforcement and penalties, violations might be subject to penalties of unlawful discriminatory practice.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Westchester County, NY</td>
    <td>11/6/2022</td>
    <td>
      <p>Employers must include a range of pay including both the minimum and maximum pay for the position. This is for all new job positions, promotions, and transfers. The law applies to positions within the city and those that are remote</p>
    </td>
    <td>
      <ul>
        <li>Civil penalty: Amount not to exceed $125,000 to be paid to the County of Westchester if found to have committed an unlawful discriminatory practice.</li>
        <li>Amount not to exceed $250,000 if found to have committed an unlawful discriminatory practice which is found to be willful, wanton, or malicious intent.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Jersey City, New Jersey</td>
    <td>6/15/2022</td>
    <td>
      <p>Employers are required to include a minimum and maximum annual salary or hourly wage to postings or advertisements for positions within the city. Law does not mention remote workers.</p>
    </td>
    <td>
      <ul>
        <li>Penalty: Non-compliance include fines of up to $2,000.</li>
      </ul>
    </td>
  </tr>

  <tr>
    <td>Maine</td>
    <td>7/13/2026</td>
    <td>
      <p>Companies must include a prospective range of pay in all job postings (printed or electronic) posted by a company directly or through a third party that are open to applicants in the state of Maine, provide the pay range for a Maine worker’s current position upon request, and maintain records of each worker’s pay history and position held during their service and for three years after separation.</p>
    </td>
    <td>
      <ul>
        <li>Maine has already allocated funding for a dedicated Department of Labor inspector to enforce these rules, so we can expect strict compliance oversight.</li>
      </ul>
    </td>
  </tr>
</table>