Beginning October 27, 2025, Cleveland employers with 15 or more employees will need to comply with the city’s new pay transparency and compensation history requirements. Ordinance No. 104-2025 prohibits covered employers from asking applicants about their salary history, including benefits, and bars employers from using compensation history to screen candidates or make hiring decisions. Employers must also include salary ranges or pay scales in all job postings.

The ordinance provides limited exceptions, such as internal transfers or promotions, voluntary and unprompted disclosures by applicants, or when compensation is governed by collective bargaining. The Fair Employment and Wage Board will enforce the new law. Upon receiving a complaint, employers will have 90 days to cure violations and may also appeal any civil penalties, which is more lenient than the five-business-day window employers have to cure deficiencies under the recent amendments to the Washington pay transparency laws.

With the compliance deadline rapidly approaching, now is the time for employers to act. Cleveland employers should take key steps:

  • Review and update all job postings to include salary ranges or scales.
  • Eliminate any application questions or interview practices that seek compensation history.
  • Train hiring managers and recruiters on compliance requirements.

If you have questions about Cleveland’s new requirements or aligning your hiring practices with evolving pay transparency laws nationwide, contact a Jackson Lewis attorney.

Tags: Ohio, Pay Transparency
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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