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Risky / jurisdiction-dependentPay transparency

Do you have to post a salary range in Vermont job postings?

Vermont's pay-transparency law generally requires employers with five or more employees to include a compensation range in job postings. The requirement is relatively new, so confirm current rules.

Vermont generally requires employers with five or more employees to disclose the compensation or a compensation range in advertisements for open positions, including remote roles that will predominantly be performed in Vermont.

The requirement took effect in 2025 and details may still be settling. Confirm the current obligations for any role that touches Vermont before relying on them.

Risky phrasing

Burlington. Office Manager. Pay negotiable.

Compliant rewrite

Burlington. Office Manager. $48,000–$56,000 per year. (Vermont generally requires a compensation range; confirm current rules.)

The law at a glance

Law
Vermont Act 155 (H.704) — Disclosure of Compensation to Prospective Employees21 V.S.A. § 495p (added by Act 155 of 2024, H.704 — formally 2023, No. 155 (Adj. Sess.))
In effect
July 1, 2025
Who’s covered
Employers with five or more employees, at least one of whom works in Vermont — a reading stated expressly in the Vermont Attorney General's guidance, since the statute itself does not say where the five must be located.
Penalties
The pay-transparency section itself does not list a fixed dollar penalty. Under 21 V.S.A. § 495b(a)(1), the Vermont Attorney General or a State's Attorney can seek civil penalties, restitution of wages or other benefits, reinstatement, and investigation costs using the civil-enforcement procedures in 9 V.S.A. §§ 2458–2461, as though a violation were an unfair act in commerce. Confirm current exposure with counsel.

What that means for a posting

  • Include the compensation or a compensation range in any written advertisement for a specific job opening. The range means the minimum and maximum annual salary or hourly wage the employer expects in good faith to pay at the time the advertisement is created — and the statute expressly allows hiring for more or less than the posted range based on circumstances outside the employer's control, such as an applicant's qualifications or labor market factors.
  • The rule covers jobs physically located in Vermont and remote roles that will predominantly perform work for an office or work location physically located in Vermont.
  • It applies to internal and external postings alike, including transfer and promotion opportunities. The Attorney General's guidance treats an internal email seeking applicants for a specific opening as a covered advertisement.
  • Commission-based roles (in whole or in part) must disclose that fact but are not required to list a range. Tipped roles must disclose that they are tipped and include the base wage or range of base wages the employer in good faith expects to pay.
  • General announcements like "We're Hiring" or "Join our Team" that do not identify a specific position, and verbal announcements (in person, radio, television, or other electronic media), are not covered.
  • Retaliation is separately prohibited: refusing to interview, hire, promote, or employ someone for asserting rights under this section is itself a violation.

Remote and out-of-state postings

Remote roles are covered when the work will be performed predominantly for an office or work location physically located in Vermont. An out-of-state employer is generally covered if it has five or more employees and at least one works in Vermont, per the Attorney General's guidance. The statute expressly excludes positions physically located outside Vermont that perform work predominantly for offices or work locations outside Vermont.

How it’s actually enforced

For most employers, Act 155 is enforced by the Vermont Attorney General's Office — its Civil Rights Unit, per the AG's own guidance — with the statute also authorizing a State's Attorney to act, using the same civil tools as Vermont's consumer-protection statutes: civil investigations, assurances of discontinuance, and court actions seeking civil penalties and wage restitution. The Vermont Human Rights Commission has exclusive authority only where the State of Vermont itself is the employer. There is no private right of action — the AG's guidance says individuals cannot go to court themselves and should instead contact the Civil Rights Unit or the Commission. The softer side: the Attorney General led with compliance-focused guidance published before the effective date, and as of this writing no wave of Vermont enforcement actions has been reported.

Common follow-ups

Does Vermont's law apply to remote jobs or out-of-state employers?+

Generally yes, in two situations. A remote role is covered when the work will predominantly be performed for an office or work location physically located in Vermont. And an out-of-state employer is generally covered once it has five or more employees with at least one working in Vermont, per the Attorney General's guidance. A remote job performed entirely outside Vermont for non-Vermont locations is expressly excluded — but confirm the specifics with counsel before relying on that.

Do internal promotions and transfers need a posted range?+

Generally yes. The statute covers positions open to internal candidates, external candidates, or both, including transfer and promotion opportunities. The Attorney General's guidance goes further: an internal email seeking applicants for a specific Vermont-based opening counts as an advertisement and needs the range. A general "join our team" message that names no specific position does not.

What about commission-based or tipped positions?+

They get their own rules. An ad for a job paid on a commission basis, in whole or in part, must say so but is not required to include a compensation range. An ad for a tipped job must disclose that it is tipped and include the base wage or range of base wages the employer in good faith expects to pay — base wage meaning the hourly wage the employer pays, not counting tips.

Who enforces the law, and can applicants sue?+

The Vermont Attorney General's Office (its Civil Rights Unit) enforces it for most employers, with the statute also naming State's Attorneys; the Human Rights Commission has exclusive authority only when the State of Vermont is the employer. There is no private right of action — the Attorney General's guidance says individuals cannot go to court themselves and should contact the Civil Rights Unit instead. Retaliating against someone for asserting rights under the law — refusing to interview, hire, promote, or employ them — is separately prohibited.

Does the posted range have to be exact, and can we still negotiate?+

The range must reflect the employer's good-faith expectation of the minimum and maximum annual salary or hourly wage at the time the ad is created — and the statute defines good faith simply as "honesty in fact." The law expressly allows hiring for more or less than the posted range based on circumstances outside the employer's control, such as an applicant's qualifications or labor market factors, and the Attorney General's guidance confirms both sides remain free to negotiate pay during the application or hiring process.

Do bonuses, equity, or benefits have to be in the posting?+

The required disclosure is the annual salary or hourly wage range — the statute's definition of "range of compensation" does not mention bonuses, equity, or benefits, and the law as written does not appear to require disclosing them. Commission and tipped pay have their own specific rules. Confirm with counsel how to describe variable pay for a specific posting.

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Sources

Last reviewed July 8, 2026. Laws change — always confirm current rules for your jurisdiction.FairHire is an informational tool, not legal advice. Have qualified counsel review your hiring questions before use.