Countdown to Compliance: Cleveland Employers Prepare for New Pay Transparency Requirements

Jackson Lewis P.C.
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Beginning October 27, 2025, Cleveland employers with 15 or more employees will need to comply with the city’s new pay transparency and compensation history requirements. Ordinance No. 104-2025 prohibits covered employers from asking applicants about their salary history, including benefits, and bars employers from using compensation history to screen candidates or make hiring decisions. Employers must also include salary ranges or pay scales in all job postings.

The ordinance provides limited exceptions, such as internal transfers or promotions, voluntary and unprompted disclosures by applicants, or when compensation is governed by collective bargaining. The Fair Employment and Wage Board will enforce the new law. Upon receiving a complaint, employers will have 90 days to cure violations and may also appeal any civil penalties, which is more lenient than the five-business-day window employers have to cure deficiencies under the recent amendments to the Washington pay transparency laws.

With the compliance deadline rapidly approaching, now is the time for employers to act. Cleveland employers should take key steps:

  • Review and update all job postings to include salary ranges or scales.
  • Eliminate any application questions or interview practices that seek compensation history.
  • Train hiring managers and recruiters on compliance requirements.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations. Attorney Advertising.

© Jackson Lewis P.C.

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