Connecticut employers will soon need to provide pay transparency disclosures in their internal and external job postings.

New Posting Requirements

Under Public Act 26-12 (House Bill 5003), which goes into effect on Oct. 1, 2026, employers must disclose the wage or wage range for positions in internal or external job postings. Currently, when in the process of hiring a new employee, Connecticut employers are only required to provide the wage range upon an applicant’s request, prior to or at the time of an offer of compensation, or at the time of hire. The new law will require employers to be transparent about wages from the outset.

Not only will employers need to disclose wage information in their job postings, but they will also be required to include a general description of benefits.

Importantly, the new law answers an open question about the applicability of the statute to out-of-state employers and employees. It provides: “The provisions of this section shall apply to any position in which the duties of such position will be performed within the state or in which the duties for such position will be performed outside of the state but requires the employee performing such duties to report directly to a supervisor, office or other worksite located within the state.”

The statute also closes other gaps in the pay transparency timeline. If an employer has not posted a position, then the same information must be provided before any compensation discussion. For existing employees, the same information must be provided at hire, at role change, and upon request.

The new law also prohibits retaliation against applicants or employees who exercise their rights and clarifies that a private right of action must be brought within two years of the claimed violation. The new law also removes punitive damages as a category of recoverable damages.

Open Questions

The statute defines “wage range” as the range the employer “sets in good faith for a position,” which may be based on a pay scale, a previously determined range, the actual range for comparable employees, or the employer’s budgeted amount. It also defines “benefits” as “health insurance benefits, retirement benefits, fringe benefits, paid leave and any other compensation other than wages to be offered with a position.”

What this means in practice is still to come. Other states with similar pay transparency laws have taken different paths on the level of required detail, particularly for benefits descriptions and the breadth of wage ranges.

Employers should monitor for forthcoming guidance from the Connecticut Department of Labor.

Takeaways

Once the new law goes into effect, employers should plan to include wage and benefits information in job postings. When no position is posted, employers still should be prepared to provide the required information before compensation is discussed. Employers should review their hiring and posting practices now to ensure the ranges they publish and the benefits they describe are accurate, supportable, and consistently applied.

If you have questions about these developments or would like to discuss national pay transparency compliance, please contact a Jackson Lewis P.C. attorney. Our Workplace Analytics and Preventive Strategies practice group is tracking these requirements nationwide.

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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.