Pay transparency

Pay transparency laws by country: a 2026 employer guide

Salary-range rules differ by country, and even by US state. Here's a sourced country-by-country guide to where you have to publish pay — the EU, UK, US states, and Canada.

June 14, 2026 · 9 min read

There is no single "pay transparency law." If you hire across borders — or even across US state lines — you're dealing with a patchwork of rules that differ on who's covered, what you have to publish, and when. This guide walks through the major regimes as they stand in 2026, with sources for each. It's a map, not legal advice: always confirm the current text for the specific jurisdiction you're hiring in.

European Union

The EU Pay Transparency Directive (Directive (EU) 2023/970) set 7 June 2026 as the deadline for member states to write it into national law. The core obligations:

  • Candidates must be told the initial pay or pay range before the interview, in the advert or beforehand.
  • Employers cannot ask about pay history.
  • Workers have a right to pay information for themselves and for the average of colleagues doing equal work, by sex; pay-secrecy clauses are banned.
  • Gender pay-gap reporting for employers with 100+ staff, phased from 2027, plus a mandatory joint pay assessment if an unjustified gap of 5% or more appears.

Crucially, the Directive sets a floor — each member state transposes it individually, and some go further. Note that transposition has been uneven: an industry tracker found that as of 20 May 2026, only 2 of 27 member states had passed comprehensive transposition legislation, with several announcing delays. Confirm the national law where you operate. Sources: European Commission, Syndio transposition tracker. We cover the gap-reporting side in detail in our 2027 reporting guide and the full obligations in our compliance checklist.

United Kingdom

The UK is not covered by the EU Directive. It has no general requirement to publish salary ranges in job adverts. What it does have is gender pay-gap reporting for employers with 250+ relevant employees, in force since 2017, plus a government pay-transparency pilot encouraging (not mandating) employers to show salaries in ads. Practically, the direction of travel is toward more disclosure even without a mandate. Sources: GOV.UK, WTW.

United States

There is no federal pay-transparency law. Instead it's a state-by-state (and sometimes city-by-city) patchwork. One 2026 employer guide counts 16 states plus Washington, D.C. with statewide wage transparency laws. A few of the most significant:

  • Colorado — the first state to require range disclosure in postings (effective 1 January 2021); applies to employers with at least one Colorado employee; must disclose compensation range plus a general description of benefits.
  • California — employers with 15+ employees must include the pay scale in all job postings; a 2026 amendment redefines "pay scale" as a good-faith estimate of what the employer reasonably expects to pay.
  • New York State — employers with 4+ employees must include a good-faith salary range in postings for roles performed at least partly in New York (effective 17 September 2023).
  • Washington — employers with 15+ employees must include a salary range plus a general description of benefits and other compensation on all postings (effective 1 January 2023).
  • Illinois — employers with 15+ employees must include pay ranges and a general description of benefits in job advertisements.

The common thread: a "good-faith" range you genuinely expect to pay — not a placeholder spread to preserve negotiating room. Sources: Jackson Lewis, Paycor (state count), New York DOL.

Canada

Like the US, Canada regulates this at the provincial level:

  • British Columbia — employers must include wage or salary information on publicly advertised job postings (effective 1 November 2023).
  • Ontario — the Pay Transparency provisions require salary ranges in publicly advertised postings, applying primarily to employers with 25+ employees (effective 1 January 2026).
  • Prince Edward Island — employers must include the expected pay or pay range in publicly advertised postings, and cannot seek applicants' pay history.

Sources: Mercer Canada, Robert Half (Ontario).

What this means if you hire across borders

The thresholds, triggers, and disclosure points don't line up — a 200-person company can be out of scope for EU gap reporting, in scope for UK reporting, and subject to range-posting rules in five US states at once. The practical response isn't to track every rule reactively; it's to build one defensible pay structure — objective, documented ranges per role and level — that satisfies the strictest regime you touch. Do that, and most jurisdictions become a publishing decision rather than a redesign.

How Remunara helps

That single defensible structure is exactly what we build. Our advisory team designs pay grades and ranges on objective, gender-neutral criteria, and the platform keeps them current as laws and markets move — so a new disclosure rule in another country is a setting you switch on, not a fire drill.

This article is general information, not legal advice. Pay-transparency laws change frequently and apply differently by jurisdiction, employer size, and role location — confirm the current requirements for each place you hire.

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