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.

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Photo of Laura A. Mitchell Laura A. Mitchell

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating…

Laura Mitchell is a principal in the Denver office of Jackson Lewis P.C. and leads the firm’s Workplace Analytics and Preventive Strategies Pay Equity subgroup. She partners with employers to evaluate, develop and implement policies and practices that ensure workplace fairness while mitigating legal risk. Laura is a guiding force in the firm’s most specialized and technical practice areas where she leverages an analytics-focused approach to partner with her clients in building legally compliant programs around which they can anchor their workplaces achieving productivity and stability.

Laura understands that creating a competitive advantage for employers in today’s workplace involves using a data-driven approach to counsel companies on the development of proactive and equitable non-discriminatory practices in hiring, promotions, separations and pay—and where advancements in technology can create both opportunities for efficiencies and risk that can be measured. Committed to putting her clients’ organizational goals first and foremost while balancing legal risk, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication. Staying the course with employers across their organizational journey while balancing legal compliance obligations throughout their employees’ lifecycle ensures Laura’s position as a go-to resource.

Laura works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize the combined vision of legal compliance, increased productivity and economic growth enhanced by a focus on pay equity.  As part of the pay equity journey, she advises employers on the evolving pay transparency landscape, working to align compliant practices with the practical realities of the business world.

Laura partners closely with government contractors to understand, implement and demonstrate compliance with their EEO regulatory and compliance obligations. She also works closely with non-government contractor clients to conduct risk assessments of their programs, policies, and training to align with federal and state anti-discrimination requirements.

Laura is the editor and a principal contributor of the GovCon Employment Exchange blog and presents on pay equity and government contractor obligations. To round out her days, Laura enjoys spending time with her family and friends attending sports events, working out, riding her bike, playing pickleball and taking in Colorado’s incomparable sunsets.