Pay Transparency Now Mandatory in Cleveland Job Postings
Cleveland has joined a growing national movement aimed at increasing pay equity and closing the wage gap. Under Ordinance No. 104-2025, passed by Cleveland City Council on April 28, 2025, and effective October 27, 2025, employers are now required to include salary ranges in all job postings. Non-compliance could result in escalating fines and public scrutiny. This legal update has major implications for small and mid-sized businesses that operate within city limits — and potentially beyond.
What Does the Law Require?
Mandatory Disclosure in Job Listings
The ordinance mandates that any employer with 15 or more employees and at least one working in Cleveland must clearly state the minimum and maximum salary or hourly wage for every posted job opportunity. This applies to internal promotions and external hiring alike.
Enforcement and Penalties
Failure to comply could result in serious financial repercussions. The penalty structure is:
$1,000 for a first offense within five years
$2,500 for a second offense within five years
$5,000 for each offense after the second within five years
In addition to these fines, enforcement measures include:
Investigations initiated by the Fair Employment Wage Board
Public disclosure of non-compliant employers
Legal complaints by affected job applicants
Who Must Comply?
This law applies to:
Private employers with 15 or more employees
Businesses with at least one employee working in Cleveland
Employers advertising remote jobs that may be performed in Cleveland
A Gray Area for Remote Listings
Whether the law applies to companies based outside Cleveland posting remote jobs that could be performed within city limits is currently a legal gray area. Until clarified, employers should err on the side of compliance to avoid penalties and reputational harm.
Salary History Inquiries Now Unlawful
In addition to salary disclosure requirements, the ordinance makes it unlawful for a covered employer to:
Inquire about an applicant’s salary history
Screen applicants based on their current or past salary
Rely solely on salary history to determine whether to offer employment or to set compensation
Retaliate or refuse to hire an applicant who does not disclose salary history
These provisions align with a national trend toward fair pay laws that prevent historical inequities from following workers across jobs.
Compliance Tips for Employers
1. Conduct a Pay Equity Audit
Before disclosing salary ranges, assess whether your compensation practices are legally defensible and equitable. Review:
Wage gaps across race, gender, and age
Role classification and job description accuracy
Salary band consistency across roles and departments
Document findings and correct unjustified disparities proactively.
2. Establish Salary Bands
Base your ranges on:
Market and industry benchmarks
Your internal compensation philosophy
Role-specific skills, education, and experience
Avoid excessively wide ranges — typically, a 10–20% spread is appropriate.
3. Train Hiring Managers and Recruiters
Everyone involved in recruitment should understand:
How to communicate pay ranges effectively
How to handle negotiations legally and ethically
Why retaliation or biased hiring decisions can violate the law
Training should also cover new salary history prohibitions.
4. Update All Job Postings
Every job listing, whether posted on:
Your company website
LinkedIn
Indeed
Third-party recruiters
Must include:
Salary or hourly wage range
Job location (on-site, hybrid, remote)
Benefits and perks (optional but encouraged)
Consistency across platforms is key to reducing liability.
Practical Benefits of Compliance
Despite initial concerns, employers often find pay transparency:
Reduces turnover by building trust
Attracts better talent
Strengthens employer branding
Narrows pay gaps for women and minority applicants
Complying with the ordinance can ultimately give your business a competitive edge in a tight labor market.
How Gertsburg Licata Can Help
We assist businesses with:
Custom compensation audits
Developing compliant hiring policies
Updating job descriptions
Multi-jurisdictional compliance strategies
To discuss how these changes impact your organization and to create a proactive compliance plan, contact us today at 216-573-6000 to speak with one of our experienced Labor and Employment attorneys.
Sources
- City of Cleveland Pay Transparency Ordinance (April 2025)
- Rizo v. Yovino, 950 F.3d 1217 (9th Cir. 2020)
- U.S. Department of Labor, 2023 Gender Wage Gap Statistics
- LinkedIn Salary Transparency Survey (2022)
- Colorado Equal Pay for Equal Work Act Report (2023)
Disclaimer
The information provided in this article is intended for general informational purposes only and should not be construed as legal advice. It does not establish an attorney-client relationship, and any reliance on the information contained herein is done at your own risk. For specific legal guidance tailored to your business and jurisdiction, it is recommended to consult with a qualified attorney who can provide professional advice based on your unique circumstances.
