Vermont will join a growing list of states and jurisdictions that require employers to disclose compensation in job advertisements on July 1, 2025. This new law applies to employers with five or more employees and to job openings that are either physically located in Vermont or remote positions that will predominantly perform work for an office or work location physically located in Vermont. The covered job openings are positions open to internal or external candidates or both, including positions into which current employees can be transferred or promoted.

The pay transparency law requires advertisements of job openings in Vermont to include the compensation or range of compensation, defined as “the minimum and maximum annual salary or hourly wage for a job opening that the employer expects in good faith to pay for the advertised job at the time the employer creates the advertisement.” Employers can hire a candidate for more or less than the compensation range listed in the advertisement based on circumstances outside the employer’s control, such as an applicant’s qualifications and labor market factors.

There are several exceptions to the disclosure requirement. If a position is paid on a commission basis, the job posting need only disclose that fact. Information about commission ranges is not required. Another exception is if the position is paid on a tipped basis. For these positions, the posting should disclose that fact, as well as the base wage or range of base wages exclusive of tips.

Covered job postings include any written notice for a specific job opening. If the advertisement is either a general announcement that notifies potential applicants of employment opportunities with the employer but does not identify any specific job openings; or a verbal announcement made in person or on the radio, television, or through other electronic means, the compensation disclosure requirements do not apply.

Unlike many other states and jurisdictions, there is no requirement to list other forms of compensation and benefits.

The new law will be enforced by the Vermont Attorney General’s Office. On or before January 1, 2025, the Office will publish guidance regarding the pay transparency law on its website for employers and employees.

In addition to its pay transparency requirements, it is a violation for an employer to refuse to interview, hire, promote, or employ a current or prospective employee for asserting or exercising any rights provided by the pay transparency law.

Employers with five or more employees that advertise for job openings that are either physically located in Vermont, or for remote positions that will predominantly work for an office in Vermont, should:

• Review their pay structures to ensure that pay ranges are consistent within and across roles
• Ensure their recruiting team (and any third-party recruiters) have access to pay information and standardized and consistent language for use in postings
• Establish an audit process to ensure job postings and advertisements include the required compensation information
• Provide hiring managers access to information about salary ranges for positions on their team, including vacant positions, to better prepare them for compensation negotiations
• Provide hiring managers and recruiters with best practices guidance regarding how to set offers within ranges, document that decision-making, discuss salary ranges with candidates, and respond to questions about placement in range and other negotiation scenarios