With enforcement deferred until January 1, 2027, employers have over a year to prepare for the changes.

Effective December 3, 2025, Columbus, Ohio, will be the latest in a growing list of jurisdictions across the country to mandate salary information in job postings. After unanimous approval by the City Council, the mayor signed into law Ordinance No. 2898-2025 on November 4, 2025, to strengthen the city’s existing pay equity law. Whereas the original law told employers what they could not do, the ordinance compels specific actions.

Pursuant to the ordinance, covered Columbus businesses must state salary information in all job postings, with limited exceptions, in addition to complying with the existing restrictions on use of salary history information. The ordinance applies to businesses employing 15 or more individuals in Columbus, as well as job placement and other employment agencies that operate on behalf of such employers. With enforcement deferred until January 1, 2027, employers have over a year to prepare for the changes.

New Pay Transparency Provisions

The ordinance requires employers to include a “reasonable” salary range or salary scale in any employment posting. It defines a covered “posting” to include any solicitation intended to recruit applicants for a specific job, whether the posting is made electronically or in hard copy form, and it defines “salary” to include not just an individual’s wages, commissions and hourly earnings, but also the more amorphous “monetary earnings.”

Instead of defining the term “reasonable,” the ordinance provides a list of nonexclusive factors to be considered in deciding whether a given salary range or scale meets the reasonableness standard. The factors are as follows:

1. The flexibility of the employer’s budget;
2. The range of experience the employer anticipates job applicants may have;
3. The potential variation in the responsibilities of the position;
4. The opportunities for growth in and beyond the posted position;
5. The cost of living for the various locations in which an applicant may work; and
6. Market research on comparable positions and salaries.

The ordinance makes clear that the new salary posting requirement does not apply to postings that involve an internal transfer or internal promotion of a current employee.

There are multiple other exceptions to the salary posting requirement codified in the ordinance. Among other exceptions, the ordinance does not apply to postings for positions in which a collective bargaining agreement governs the compensation for the job.

Existing Pay Equity Provisions

The amendments leave unchanged the pay equity provisions of the Columbus ordinance, and the exceptions to them, that have been in effect since March 1, 2024. Employers continue to be restricted from asking job applicants about their current or prior wages, benefits or other compensation, with certain exceptions. Likewise, employers may not screen out applicants whose prior wages are greater or less than a target amount. Employers also may not use an applicant’s prior pay amount to determine the salary, benefits or other compensation to offer the applicant during the hiring process.

The anti-retaliation provision of the ordinance also remains in effect. It is unlawful for covered employers in Columbus to refuse to hire or otherwise disfavor job applicants because they did not disclose their salary history.

Penalties for Violations

The ordinance does not give individuals the right to sue for violations. Rather, enforcement is the responsibility of the Columbus Community Relations Commission (CRC). Individuals have six months to file a complaint of alleged violation of the ordinance with the CRC. If the CRC investigates the complaint and finds that a violation has occurred, the CRC may impose a civil monetary penalty on the employer.

What This Means for Employers in Columbus

Ahead of the January 2027 enforcement date, Columbus employers should make compliance with the ordinance an agenda item for 2026. With the salary disclosure obligations comes new legal risk for Columbus employers. The absence of a bright-line rule to guide employers on what salary range will be considered “reasonable” leaves Columbus businesses with uncertainty as to whether their posted salary information will be compliant.

Among other steps, Columbus employers may want to take the following steps to prepare for the new salary disclosure requirements:

1. Evaluate existing and forecasted salary information to prepare for posting salary ranges or salary scales in job postings.
2. Consider the potential benefits of undertaking an internal pay audit with your counsel on an attorney-client privileged and confidential basis.
3. Educate hiring personnel, recruiters and others who interface with job applicants about the existing and expanded requirements of the ordinance.
4. Consider how the publishing of salary information in job postings will impact your strategy for attracting job candidates.

Across the country, state and local legislatures are reshaping the salary conversation in the hiring process with pay equity laws. In 2025 alone, new pay equity laws governing private employers took effect in Illinois, Massachusetts, New Jersey, Vermont, Minnesota and Cleveland, Ohio. Employers with multistate operations ought to consider the impact of pay equity laws in all jurisdictions in which they are hiring, not just in those states and/or cities where they are subject to legal restrictions. Pay equity laws give rise to a host of legal, operational and morale considerations. Businesses that do not consider the full scope of issues these laws may trigger face not just legal risk, but competitive disadvantage in the marketplace for top talent.

For More Information

If you have any questions about this Alert, please contact Eve I. Klein, Kathryn R. Brown, any of the attorneys in our Employment, Labor, Benefits and Immigration Practice Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.