The Clock is Ticking: The Massachusetts Pay Transparency Act Compliance Deadline is Here

If you’re an employer in Massachusetts with 25+ MA-based employees still scrambling to understand the Pay Transparency Act requirements, you’re not alone. The deadline for compliance is October 29th and while the state will issue penalties for non-compliance in the future, it’s best to get compliant now!

What’s at Stake
The Massachusetts Pay Transparency Act fundamentally changes how employers communicate about compensation. Gone are the days of vague “competitive salary” job postings. Starting now, Massachusetts employers must include specific pay ranges in all job postings share this information with current employees upon request. Employers must also maintain documentation of pay practices for compliance purposes.

Key Requirements You Can’t Ignore                                                                                                                           The Act’s requirements are straightforward but comprehensive:

• Mandatory Salary Range Disclosure: Every job posting must include the position’s salary range—not just “DOE” (depending on experience) or “competitive compensation.
• Internal Transparency: Current employees have the right to request and receive pay range information for their positions. Employers need processes to handle these requests promptly and consistently.
• Internal Communication: Decide who will work with internal employees regarding salary range discussions and ensure consistent messaging.
• Anti-Retaliation Protections: Employees discussing pay are protected from retaliation.
• Documentation Requirements: Maintaining proper documentation of pay practices isn’t optional—it’s your defense against potential claims.

Safe Harbor Window
Massachusetts provides a safe harbor provision for salary-range postings without a proper pay range, offering a 2-day fix window—through October 29, 2027. This grace period allows employers to correct posting errors quickly, but it won’t protect you from willful non-compliance or systemic failures.

Practical Steps for Immediate Compliance
Here is your action checklist:

1. Audit Current Job Descriptions: Job descriptions are the cornerstone of accurate pay ranges.. Ensure they reflect the most up-to-date duties and qualifications.

2. Establish/Review Pay Ranges: Create or review pay ranges for all positions. Consider factors like experience, education, and market rates. Additionally, factors such as impact & influence, scope of impact, decision-making authority, and autonomy should be part of the evaluation.

3. Job Postings: Revise all job posting templates to include a standard statement for salary ranges / hourly rates and include this in all posts. Remember, the posted pay range should be what you in good faith plan to pay at the time of the posting.

4. Train Your Team: Managers and HR staff should be trained as follows:

• How to communicate pay ranges to candidates
• How to respond to employee pay inquiries
• Understand anti-retaliation provisions

5. Document Your Process: Create systems to track job postings, pay decisions, range determinations, and employee inquiries.

Beyond Compliance: The Competitive Advantage

While the deadline pressure is real, smart employers recognize pay transparency as more than a compliance burden. Organizations embracing transparency report improved candidate quality, reduced time-to-hire, and increased employee trust.

Act Now
The Massachusetts Pay Transparency Act isn’t a future concern—it’s today’s reality. Every day of delay increases your risk and sends the wrong message to current and prospective employees.

Don’t wait for an enforcement action to catalyze change. Whether you need to review or overhaul your compensation structure or simply update posting templates, it’s time to get started. Your employees, candidates, and bottom line depend on it. Contact us at insource@insourceservices.com or 781-235-1490 to get started today.