Cooley·EMPLOYMENT / LABOR

New State Pay Transparency Laws Impose Wage Disclosure, Penalty Obligations

Employers operating in Virginia, Maine, Connecticut and Delaware must update hiring and compensation practices to comply with new state pay transparency rules that carry civil penalties and private lawsuit exposure.

Four states (Virginia, Maine, Connecticut and Delaware) have enacted new pay transparency laws with 2026 effective dates, imposing varying wage disclosure, recordkeeping and hiring practice requirements on employers. Virginia’s universal rule (no employee threshold) mandates good-faith wage range disclosures in all public and internal job postings, bans most salary history inquiries, and allows private lawsuits and AG enforcement with up to $5,000 in penalties for repeat violations. Maine’s rule applies to employers with 10 or more employees, requires pay range disclosures in postings and upon employee request, and mandates three years of post-employment pay recordkeeping. Connecticut’s expanded rule applies to all employers, requiring wage ranges and general benefit descriptions in all job advertisements. Employers in these states should update relevant policies and processes ahead of each law’s effective date to reduce enforcement and litigation risk.

pay-transparencyemployment-compliancewage-disclosurestate-labor-lawhiring-practices

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