Columbus is the most recent Ohio city to join the pay transparency wave. Effective January 1, 2027, employers will be required to disclose salary ranges in their job postings. This is Columbus’s first significant step to expand pay-related protections for job applicants since the city’s 2024 ban on salary inquiries. Columbus joins Cleveland as the latest Ohio city to enact pay transparency requirements for job postings.
Who must comply with the pay transparency requirements?
The pay transparency requirement applies to any person or entity that employs 15 or more employees within the City of Columbus. The Ordinance also applies to job placement and referral agencies that work for such employers.
The Ordinance’s requirements apply only to jobs that will be performed within the geographic boundaries of the City of Columbus.
What is a “posting”?
An employment posting is any solicitation intended to recruit applicants for a specific available position that also includes a description of the position or qualifications of the desired applicants. This includes postings done directly by the employer or indirectly through a third party and includes postings made electronically or via printed hard copy. It does not include postings that are replicated or published without the employer’s consent.
What must be included in job postings?
Covered employers must disclose a “reasonable salary range or scale” in their postings for new jobs. The Ordinance sets out a non-exhaustive list of factors that will determine if the salary range or scale is reasonable:
- The flexibility of the employer’s budget
- The anticipated range of experience that job applicants may have
- The potential variation in job responsibilities for the position
- The opportunities for growth in the position and beyond
- The cost of living for the various locations where an applicant may work
- Market research on comparable positions and salaries
“Salary” includes wages, commissions, hourly earnings or any other monetary earnings.
The Columbus Ordinance is lacking two provisions common in pay transparency requirements in other jurisdictions. First, it does not require disclosure of non-monetary benefits. Second, it applies only to external job postings and does not apply to positions that would involve an internal transfer or promotion.
What are the penalties for failure to comply?
There is no private right of action. Instead, applicants may file complaints with the Columbus Community Relations Commission, which can impose penalties outlined in the City Code, including imposition of fines and criminal prosecution.
Takeaways for Employers
Employers doing business in Columbus, Ohio, should review their current pay rates, hiring practices, promotion practices and postings in anticipation of the January 1, 2027, effective date.
Jurisdictions continue to enact pay transparency (job posting) requirements. For example, Illinois, Massachusetts, Minnesota, New Jersey, Vermont and Cleveland, Ohio, all had pay transparency laws take effect in 2025.
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