The Massachusetts Pay Transparency Act, officially titled the Frances Perkins Workplace Equity Act, was signed into law on July 31, 2024. Set to take effect in stages beginning in 2025, the law imposes new obligations on employers aimed at increasing wage transparency and pay equity across the Commonwealth. For employers operating in Massachusetts, now is the time to understand the law’s requirements and prepare for the changes ahead.

Major Requirements of New Law

The new Massachusetts law introduces two major requirements: wage data reporting and salary range disclosures. Employers with 100 or more employees in Massachusetts are required to submit federally mandated wage data reports—such as EEO-1, EEO-3, and EEO-5—to the Massachusetts Secretary of State starting February 1, 2025. These are not new reports but rather copies of those already submitted to federal agencies. The EEO-4 will be added to the reporting list beginning in 2026. Once submitted, this data will be aggregated and made publicly available by the state.

In addition to wage data reporting, employers with 25 or more employees, including remote workers who report to Massachusetts-based offices, will be required to include salary ranges in job postings starting October 29, 2025. They must also provide salary ranges upon request to current employees, regardless of whether a job is actively posted. These ranges must reflect what the employer “reasonably and in good faith” expects to pay for a given role.

Consequences for Not Following the Law

Enforcement of the salary range provision is under the exclusive jurisdiction of the Attorney General’s Office. Employers found in violation will first receive a warning. Penalties increase with repeated offenses, starting at $500 and rising to as much as $25,000 for persistent non-compliance. Importantly, for the first two years following the law’s effective date, employers will be given two business days to cure any salary range violation after receiving notice from the state. Even though the initial penalties are modest, the public disclosure of wage data and salary ranges introduces broader risks.

Employers should expect employees to take note of posted salary ranges and ask questions—sometimes uncomfortable ones—about pay equity. If a current employee notices a posted range that exceeds their salary for the same role, they may request a raise. Employers should be ready to respond with clear, objective reasoning based on established salary criteria. In cases where an objective explanation is lacking, the prudent response may be to adjust the salary accordingly. These situations underscore the need for internal alignment among HR, management, and legal teams to ensure consistent, fair, and well-documented compensation practices.

Employers Need to Protect Themselves

To mitigate risk and build trust, employers are encouraged to proactively conduct internal pay equity audits. These self-evaluations not only help identify and correct discrepancies but also serve as an affirmative defense under the Massachusetts Equal Pay Act—provided they are documented, reasonable in scope, and completed within the past three years. Employers should make measurable progress toward eliminating wage differentials and maintain records of any changes implemented.

Establishing and maintaining well-defined salary ranges is now a business imperative. Employers should base these ranges on market research, geographic cost of living, and industry benchmarks. They should consider factors such as seniority, performance metrics, production output, geographic location, education, and experience, applying them uniformly across comparable roles. Regular reviews are essential to ensure salary ranges remain aligned with market conditions and internal expectations. Employers must also reassess positions periodically, especially as roles evolve or teams consolidate.

Additional Steps

Transparent communication will be just as important as compliance. Companies should consider sharing internal memorandums when posting new jobs, clarifying how salary ranges are determined, and setting expectations for how employees can move within those ranges. Training managers on how to communicate compensation is critical. A lack of coordination can lead to inconsistent messaging and employee dissatisfaction. To prevent this, employers should implement a centralized oversight process, especially for salary adjustments and raises.

The Massachusetts Pay Transparency Act introduces a more transparent compensation framework, but it also places the burden on employers to manage the cultural and practical challenges that come with greater visibility. By taking early, thoughtful steps—such as conducting pay audits, developing consistent salary ranges, and training leadership—employers can not only comply with the law but also foster a more equitable and engaged workforce.

For further guidance, employers can review the official Attorney General’s Office Guidance on the Wage Transparency Act.