US pay transparency laws in 2027: state dates

Three dates fall in 2027 among the 17 US jurisdictions checked. Washington’s cure period ends on Tuesday, July 27, Delaware’s pay range law starts on Sunday, September 26, and Massachusetts’ cure period runs until Friday, October 29. Delaware’s is the only pay range law among the 17 that starts in 2027, and it covers employers with more than 25 employees. A cure period gives an employer a short window to correct a defective posting after notice. The list covers 15 states plus New York City and D.C., and 16 of the 17 already apply on the pages read. This page did not check 2026 session laws, so a law signed this year is not counted.

Massachusetts covers employers with 25 or more employees, and Delaware exempts employers with 25 or fewer. An employer with exactly 25 employees whose primary place of work is Massachusetts is therefore covered there and, if it has 25 employees in total, exempt in Delaware, although Massachusetts averages headcount over the payroll periods of a year, as the headcount section below explains. Every date below was checked against a state or city source on October 27 or 28, 2026. Two states are the exception, California and Nevada, because the pages read give no start date for California’s original posting rule or for Nevada’s rule.

Delaware’s law starts on Sunday, September 26

House Substitute 2 for House Bill 105 was signed on September 26, 2025. It is Chapter 228 of Volume 85 of the Laws of Delaware. The bill page lists 9/26/27 as the effective date, and the Act says it takes effect 2 years after its enactment into law. September 26, 2027 is a Sunday, so the first business day under the law is Monday, September 27.

For employers with 26 or more employees, the section applies to jobs located in Delaware and to non-international remote positions offered by an employer based in Delaware. Postings must carry the pay range and a general description of the benefits. The Department of Labor administers and enforces the section. A first offense brings a written warning. Any second or later offense carries a civil penalty of $500 to $10,000. Temporary, interim or acting jobs that need an immediate hire are exempt. The Act also lets a commission-paid job disclose only that fact, and a tipped job disclose the base wage or range.

Our view is to have the Delaware posting template approved by Friday, September 24, 2027, the last business day before the law starts. The Act gives a warning for a first offense and a penalty from the second, so a template error copied into many postings is cheapest to fix before any warning.

Washington’s cure period ends July 27, 2027

For postings from July 27, 2025 through July 27, 2027, Washington requires that an employer be given a chance to correct a violation before a job applicant can seek remedies. Any person may send the employer written notice that a posting does not comply, and one such notice counts as adequate notice for the duration of that posting for any applicant seeking remedies. If the employer corrects the posting within 5 business days of receiving the notice, and where applicable demands a correction from any third-party site that carries it, neither the department nor a court may impose a penalty or award damages or other relief for the violation.

The text then says this subsection “does not apply after July 27, 2027.” That date is a Tuesday. Remedies for a violation run two ways. After a complaint, the department may order the employer to pay each affected applicant or employee statutory damages of $100 to $5,000 per violation, and may also assess a civil penalty of up to $500 for a first violation or up to $1,000 for a repeat violation. The department may also order payment of its costs of investigation and enforcement, and a prevailing applicant or employee is entitled to costs and reasonable attorneys’ fees. An applicant or employee may instead bring a civil action for the same $100 to $5,000 per violation plus attorneys’ fees and costs, within 3 years of the date of the alleged violation, and may be awarded damages by the department or the court but not both. The posting rule covers employers with 15 or more employees.

Treat the window as a backstop for postings you have already fixed. A notice can come from any person, and the correction step includes a demand to any third-party site that carries the posting, so a notice that sits in a general inbox can use most of the 5 business days. Send written notices about postings to the person who can edit them, and audit every Washington posting before July 27.

Massachusetts keeps its cure period until October 29, 2027

Massachusetts requires employers with 25 or more employees with a primary place of work in Massachusetts during the prior calendar year to disclose wage ranges, starting October 29, 2025. The Attorney General’s FAQ says employers should calculate headcount once per year, as an average over all of the payroll periods of that year, and the count includes full-time, part-time, seasonal and temporary employees. Until October 29, 2027, a Friday, a covered employer has 2 business days to cure defects after a Notice to Cure letter from the Attorney General’s Office. That is shorter than Washington’s 5 business days. A covered employer found in violation faces a warning for the first offense, a fine of not more than $500 for the second and not more than $1,000 for the third. A fourth or later offense is subject to paragraphs (1) and (2) of subsection (b) of General Laws chapter 149, section 27C, whose amounts were not read.

The same page lists a separate cure period for the Act’s EEO data reports, which runs until October 29, 2026. Do not read it as the pay range date. The duty reaches positions that can be performed remotely to a Massachusetts worksite, and employees can ask for the pay range of their current position.

Every jurisdiction checked, with start dates

“In the posting” below covers job postings and job advertisements. Thirteen jurisdictions require the range there today, and Delaware makes 14. The other three tie it to a later hiring step. Connecticut requires it for an applicant on request or at an offer. Rhode Island requires it on request, and Nevada after an interview. The three sources read for this page do not say that the range must appear in the posting.

Each law counts headcount its own way

The thresholds in the table run from one employee in Colorado, Connecticut and D.C. to 50 in Hawaii. Minnesota counts employees at one or more sites in Minnesota, and New Jersey counts employees over 20 or more calendar weeks. Massachusetts requires a primary place of work in Massachusetts during the prior calendar year and averages headcount over all of the payroll periods of a year. California’s FAQ says at least one of the counted employees must currently be located in California, while Hawaii’s flyer says the law does not specify where the 50 employees sit. Rules for remote and out-of-state roles differ again, and Pay Ranges in Job Ads: Rules by Jurisdiction sets them out jurisdiction by jurisdiction.

What we could not confirm

• Two missing start dates. For California, the DIR FAQ cites Labor Code section 432.3 and prints no effective date for the original posting rule. The legislature’s page for the section prints only the date of the 2025 amendment, and the text of SB 1162 (Chapter 559, approved September 27, 2022), a bill amending the section, prints no effective date for section 432.3. For Nevada, the chapter shows only “Added to NRS by 2021, 1678.”
• California SB 642 dates only the amendment. The Governor approved SB 642 on October 8, 2025. It was chaptered as Chapter 468 of the Statutes of 2025 and amended Labor Code section 432.3 effective January 1, 2026. The section now defines pay scale as “a good faith estimate of the salary or hourly wage range that the employer reasonably expects to pay for the position upon hire.” The DIR FAQ (page dated August 24, 2026) words its definition almost the same way, with “an employer” and “a position” where the statute says “the employer” and “the position”.
• Penalty amounts for Hawaii, Illinois, D.C., New York City and Connecticut are not on the pages read. New York Labor Law 194-b refers to a civil penalty under section 218, and the amounts were not read.
• Washington’s 2025 amendment, 2025 c 383. The RCW page prints no effective date for it.
• What applies in Massachusetts after October 29, 2027. The page is silent.
• Delaware regulations and the chaptered text. The text read is House Substitute 2 as posted on the bill page, and no Department of Labor regulations were read.
• New Jersey’s proposed rules. The page says they have not been adopted and are currently non-binding.
• Connecticut changes since 2021. The FAQ is dated September 28, 2021.
• Anything outside the 17. New York City and D.C. are in because each has a pay range rule of its own on an official page, and other cities and counties are out because no official source for them was opened. This page does not scan every state and local government. No 2026 session laws were checked. Cleveland and other Ohio cities were not compared with an official source.

What to do in your 2027 plan

1. Now: list every state where a requisition can be filled, and mark which threshold your headcount meets in each, counting the way each law counts.
2. By June 30: audit Washington postings, including copies on job boards, and route written notices to whoever edits them.
3. By Friday, September 24: approve the Delaware template if you have more than 25 employees. Check the bottom of any hourly range against Delaware’s wage floor in Minimum Wage by State 2027.
4. By October 29: make sure no Massachusetts posting lacks a range.
5. On January 12, 2027: reopen all 24 Source lines.

Put the three 2027 dates in the HR Compliance Calendar 2027, and read US Employment Law Changes 2027 for the other changes. Employers with staff in the EU face separate national deadlines, tracked in EU Pay Transparency 2027: Country Tracker.

This week, list the open requisitions that can be filled in any of the three states with a 2027 date, then check each posting against the rules in Pay Ranges in Job Ads: Rules by Jurisdiction.

Written and reviewed by the HR Riant Editorial Team. General information, not legal advice.