1 of 5

Be prepared: A Conversation on Wage Transparency Trends in the Workplace
September 21, 2023

2 of 5

Pay Transparency Legislation- Summary

2

	Proactive Disclosure in Job Postings	Upon Request/Job Applicants
California	☑	☑
Connecticut		☑
Colorado	☑	☑
Hawaii	☑
Illinois	☑
Maine (pending)	☑	☑
Maryland		☑
New York	☑
Nevada		☑
Rhode Island		☑
Washington	☑	☑
International laws: EU Equal Pay and Transparency Directive
International laws: EU Equal Pay and Transparency Directive

3 of 5

Career Progression Disclosure

3

Colorado	Illinois	European Union
Employers must make good faith reasonable efforts to “announce, post or otherwise make known” all opportunities for promotion to all current employees on the same day and prior to making a promotion decision. An employer shall disclose and make available to all eligible employees: The requirements for career progression Terms of Compensation Benefits Duties Access to further advancement	An employer shall make known all opportunities for promotion to all current employees no later than 14 calendar days after the employer makes an external job posting for the position¹	Employers must provide criteria used to determine pay levels and career progression. Pay structures must allow workers to determine if they are in comparable situation regarding the value of their work on the basis of skills, effort, responsibility, working conditions and other job related factors

¹except for positions in the State of Illinois workforce designated as exempt from competitive selection.

Colorado Effective Date: January 1, 2024.

Notice of a promotional opportunity must be: (1) in writing (which can be electronic, such as

an email or intranet posting); (2) by any method(s) reaching all employees

(3) to all employees for whom it may be a promotion, on the same calendar day

and (4) sufficiently in advance of the hiring or promotion decision that employees receiving notice may apply.

Notices of promotional opportunities are considered “job postings” and therefore must

include the compensation and benefit information required for any job posting

Once the employers selects a candidate to fill a job opportunity, the employer must make reasonable efforts to announce to employees with whom the selected candidate is expected to work the candidates: name, former job title (if current employee, and new job title.

If an employer is physically located outside Colorado and has fewer than 15 employees in Colorado wo all work remotely, then the employer is required to provide notice of only remote job opportunities.

Illinois Effective Date – January 1, 2025

4 of 5

Career Progression Disclosure

4

Colorado	Illinois	European Union
Penalty for non-compliance: fines of $500 to $10,000 for each violation	Penalty for non-compliance: fines of up to $500 for a first offense, $2,500 for a second offense, and $10,000 for a third or subsequent offense.	Penalty for non-compliance: Compensation or reparation as determined by the member State (not fixed by an upper limit)
Effective Date: January 1, 2024	Effective Date: January 1, 2025	Effective Date: tbd – three-year rollout