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Update on the District of Columbia’s Pay Transparency Law

As we previously reported, the District of Columbia (DC) had proposed a pay transparency law (B25-0194) which was signed by Mayor Muriel Bowser on January 12, 2024, making the legislation final and set to take effect on June 30, 2024. The law amends the existing Wage Transparency Act of 2014 and requires DC employers with at least one employee to post salary ranges for all job postings. The salary projections must be the minimum and maximum salary or hourly pay the employer “in good faith believes” it would pay for the role. 

In addition to wage range disclosure requirements, employers will be prohibited from asking job candidates about their past salaries or screening prospective employees based on wage history and required to disclose the existence of healthcare benefits that employees may receive before the first interview. 

Employers will also be required to post a notice in their workplace notifying employees of their rights under this act. The notice shall be posted in a conspicuous place in at least one location where employees congregate. 

Next Steps 

Before the effective date, employers should examine their compensation practices to ensure that wage ranges for open positions are in line with industry and market data for competitiveness and retention of employees. Employers will also need to review and update their job postings in addition to updating their employment applications, recruitment, and screening practices to ensure that no inquiries are made about prior salary history.  

It is recommended that employers train hiring managers and recruiters to ensure they do not inquire about prior salary history and that they properly respond to any questions or documentation related to wage information. 

Multistate employers should be mindful of any additional obligations they may have under various state-specific wage disclosure and salary history laws. 

HR Works, headquartered in Upstate New York, is a human resource management outsourcing and consulting firm serving clients throughout the United States for over thirty years. HR Works provides scalable strategic human resource management and consulting services, including: affirmative action programs; benefits administration outsourcing; HRIS self-service technology; full-time, part-time and interim on-site HR managers; HR audits; legally reviewed employee handbooks and supervisor manuals; talent management and recruiting services; and training of managers and HR professionals.