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Category: Compensation

CWC’s Filing Guide for California’s 2024 Pay Data Reporting Requirements

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has updated its Filing Guide for meeting California’s annual pay data reporting requirements. The updated guide covers the rules for filing the report for 2024, which is due May 14, 2025. This guide provides tips on the steps that a covered company should follow when pulling the data for...
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Category: Compensation

What CWC Members Need To Know About the EU Pay Transparency Directive

CWC members that have workers in any of the 27 European Union countries will have to comply with extensive pay transparency and reporting requirements beginning in 2026. Employers’ obligations under Directive 2023/970 (the Pay Transparency Directive) depend on the number of workers they have in the EU and the member states in which they work. For any employer with at...
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Category: Agency Enforcement

OFCCP Agrees to First Nationwide ERCA Since Beginning of Biden Administration

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has signed an Early Resolution Conciliation Agreement (ERCA) with State Street Corporation that includes an audit moratorium on the contractor’s establishments nationwide. Although ERCAs granting a multi-year moratorium on establishment audits were common during the previous administration, this is the first ERCA of which we are aware during the Biden...
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Category: Compensation

Private Right of Action Fuels Pay Transparency Litigation in Washington State

Washington state’s pay transparency law has generated a lot of litigation against employers since it took effect in 2023. Unlike most other state pay transparency laws, Washington’s Equal Pay and Opportunities Act (EPOA) contains a private right of action that permits employees and job applicants to sue employers for alleged infractions. Based on the impact of the controversial Washington law...
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Category: Compensation

Massachusetts Latest State To Require Pay Ranges in Job Postings

Massachusetts has become the latest state to require covered employers to post salary ranges in their job listings. H.4890, signed into law by Governor Healey on July 31, 2024, will require employers with 25 or more employees in Massachusetts to disclose pay ranges in job postings and provide a pay range to employees to whom they offer a transfer or...
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Category: Compliance Reporting and Recordkeeping

New Illinois Pay Reporting Recertification Notices Mistakenly Request Data From Wrong Year

The Illinois Department of Labor (IDOL) is issuing notices to remind employers that they must obtain a new Equal Pay Registration Certificate (EPRC) in 2024 if they obtained their initial EPRC in 2022. However, the state’s reminders included the wrong date for the employee-level compensation data that they must submit. Some of IDOL’s recertification notice emails to employers erroneously stated...
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Category: Compliance Reporting and Recordkeeping

EEOC Releases Data Dashboard of “Component 2” Pay Data to Public

The Equal Employment Opportunity Commission has made available to the public a new Data Dashboard based on data that the agency collected from employers for calendar years 2017 and 2018. The dashboard allows users to review and sort aggregate EEO-1 Component 2 pay band data. EEOC Chair Charlotte Burrows said the release of the Component 2 aggregated data can illuminate...
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Category: Compensation

Biden Administration Proposes Pay Range Disclosure Rule for Federal Contractors

The Federal Acquisition Regulatory (FAR) Council has proposed a new pay transparency rule that would require federal contractors to disclose pay ranges for all open jobs on or in connection with covered federal contracts. Two years after President Biden issued an Executive Order calling for pay transparency in federal contracting, the Biden Administration published its proposal in the Federal Register on January...
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Category: Compensation

Colorado Issues Regulatory Guidance on Its Recently Amended Pay Transparency Law

The Colorado Department of Labor and Employment (CDLE) has issued regulatory guidance on the state’s recently amended and highly prescriptive Equal Pay for Equal Work Act. The amendments go into effect January 1, 2024. Since 2021, the law has required covered employers operating in Colorado to: (1) include pay ranges in job postings for all jobs that could be performed in the...
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Category: Compensation

Recent Equal Pay Case Illustrates How Federal and State Law Outcomes Can Vary

A recent equal pay discrimination ruling by the U.S. Court of Appeals for the Second Circuit serves as a reminder that a court can reach different outcomes depending on whether it is applying federal law or a more expansive state law. In Eisenhauer v. Culinary Institute of America, a female professor for the Culinary Institute of America sued under both New York...

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