Vermont Pay Transparency Law: Employer and Job Posting Rules

Vermont’s pay transparency law, Act 155, took effect on July 1, 2025, and requires any employer with five or more employees to include a compensation range in written advertisements for specific job openings.¹ The range must be posted in good faith, meaning it reflects what the employer honestly expects to pay when the ad is created.

Which Employers Have to Comply

The five-employee threshold counts all workers, regardless of where they physically work, as long as the business operates in Vermont.¹

Remote roles are handled by where the work is directed, not where the worker sits. If a position predominantly serves a Vermont-based office or work location, the employer must comply even when the hire lives out of state. A position located outside Vermont that predominantly serves offices outside the state is not covered, even if the employer has a Vermont presence.¹ Out-of-state employers cannot avoid the disclosure requirement by placing a remote worker who reports to a Vermont office in another state.

What the Job Ad Has to Say

Every written advertisement for a specific opening must list the minimum and maximum annual salary or hourly wage the employer expects to pay at the time the ad is created.¹ The numbers must appear in the posting itself, whether it lives on a company careers page, a third-party job board, or a social media post.

The statute defines good faith as honesty in fact.¹ A range so wide it tells applicants nothing would likely fail that standard. The figures should reflect the actual budget for the role, the existing pay scale, and the qualifications required.

Benefits, bonuses, equity, and other non-salary compensation do not have to appear in the ad.² An employer can include them, but only the base salary or wage range is mandatory.

Commission and Tipped Positions

Jobs paid entirely or partly on commission have a lighter obligation. The advertisement only needs to state that the position is commission-based; no specific range or earnings estimate is required.²

Tipped positions are treated differently. The ad must disclose that the job is tipped and include the range of base (non-tip) hourly wages the employer expects to pay.² A restaurant hiring servers, for example, needs to state that the role is tipped and list the base wage range, but is not required to estimate total earnings with tips.

What Counts as an Advertisement

The requirement applies to written notices of a specific job opening shared with potential applicants. Job board listings, company website postings, email blasts, and social media posts all qualify. Verbal announcements do not, whether made in person, on the radio, on television, or in any other spoken format.¹

Generic recruitment messages are also outside the rule. A “we’re hiring” banner or a “help wanted” sign that doesn’t name a particular role or describe specific duties does not trigger the disclosure requirement.¹ The obligation kicks in only when a posting targets a defined position with identifiable duties.

Internal Postings Are Covered Too

The definition of “job opening” specifically includes positions open to internal candidates and positions into which current employees can transfer or be promoted.³ A written internal listing for a promotion must include the pay range on the same terms as any external posting. There is no carve-out for internal-only ads.

Retaliation Is Prohibited

An employer cannot refuse to interview, hire, promote, or employ someone because that person reported a non-compliant job posting to the Attorney General’s office or the Human Rights Commission.2 For applicants, that means flagging a missing pay range is legally protected. For employers, hiring managers need to know that complaints about compliance cannot factor into hiring decisions.

Enforcement and How to Report a Violation

Enforcement runs through the Vermont Attorney General’s Civil Rights Unit, which handles the state’s equal pay and fair employment cases. Non-compliant postings can be reported to the CRU at agocivilrights@vermont.gov. When the State of Vermont itself is the employer, the Vermont Human Rights Commission has exclusive enforcement authority.²

There is no private right of action. Individual applicants and employees cannot sue in court to enforce the law or seek personal damages.² The statute does not set specific fine amounts. Remedies run through the existing enforcement framework for Vermont’s fair employment practices laws, which gives the Attorney General authority to investigate, seek corrective action, and pursue penalties administratively.¹

Getting Your Postings Compliant

If your company has never assigned salary bands to positions, that work has to happen before you can post a good-faith range. Start with an internal review of what each position actually pays and what you would offer a new hire.

Then audit every active posting across every platform, including LinkedIn, Indeed, your careers page, and any other site where you recruit in writing. Each one needs a minimum and maximum salary or hourly wage that honestly reflects what you plan to pay. Commission roles need an explicit statement that the position is commission-based. Tipped roles need that disclosure plus the base wage range.

Train everyone involved in hiring. Recruiters, HR staff, and hiring managers should all understand what the law requires, what counts as a covered advertisement, and that retaliation against anyone who reports a violation is prohibited. The Attorney General’s guidance document, published in December 2024, is available on the AG’s website and is a useful starting point.²

1
Vermont General Assembly. Vermont Act 155 As Enacted
2
Office of the Vermont Attorney General. Vermont Attorney General Guidance on Act 155
3
Vermont General Assembly. Vermont Act 155 As Enacted>