Vermont Pay Transparency Law to Go into Effect

By Mitchell Chamberlin

As DCI has covered in a previous blog, a new pay transparency law is set to go into effect in Vermont starting on July 1, 2025. With the enactment of this law, known as Act 155, Vermont joins four other states with new pay transparency laws set to go into effect in 2025 and nine other states that have existing pay transparency laws.

What Are the Requirements of Vermont’s Pay Transparency Law?

Covered employers must state the compensation, or range of compensation, that they expect to pay in good faith for open positions at the time the job advertisement is created. If an open position is expected to be paid on commission, either fully or in part, the advertisement must simply state that the position is to be paid on commission. A range does not need to be included. For positions that are paid in part by tips, the job advertisement must include the range of the base wage as well as a statement indicating the position is to be paid on a tipped basis.

Which Employers Are Covered and What Positions Must Be Posted?

Under Vermont’s pay transparency law, all employers with five or more employees and at least one employee working in the State of Vermont must abide by the requirements of Act 155. Covered employers must include the required wage range information for all written notices of specific job openings that are either physically located in Vermont or remote with work predominantly performed for an office or work location in Vermont. Employers are not required to include wage range information in general hiring announcements or verbal announcements.

Guidance from the Vermont Attorney General’s Office

The Vermont Attorney General’s Office has published guidance meant to help employers comply with this Act 155. While much of it is similar to the text of the law itself, there are a few notable takeaways for employers:

• Act 155 will be enforced by the Civil Rights Unit of the Attorney General’s Office in most cases
• Act 155 does not limit the ability of employers and applicants to negotiate, nor does it limit the ability of employers to pay outside the stated range due to circumstances outside the employer’s control such as labor market factors and the worker’s qualifications
• Employers may not retaliate against individuals who notify the Attorney General’s Office of violations of Act 155

Employers looking for assistance with complying with pay transparency regulations or establishing ranges for positions can find more information on DCI’s Compensation Consulting page. DCI will continue to provide updates on state pay transparency laws as needed.