Connecticut Joins the Wage Transparency Bandwagon: Demystifying Pay Codes and Job Posting Compliance

Key Highlights

• Connecticut’s new wage transparency law adds pay code guide requirements for employers with 100 or more employees and expands wage range disclosures in job postings.
• Employers may need to update multilingual employee materials, job advertisements and timekeeping records before the Act takes effect Oct. 1, 2026.
• Employers should review commonly used pay codes, prepare required guide materials and update job postings to include good-faith wage ranges and benefits information.

Connecticut has joined a growing list of states adopting wage transparency laws, and now is a good time for Connecticut employers to start reviewing pay codes and preparing for compliance with Public Act No. 26-12, An Act Concerning Workforce Development and Working Conditions in the State. The Act imposes, among other things, new pay code transparency obligations and job posting requirements on employers effective Oct. 1, 2026. 

Pay Code Guides Required for Larger Employers

Connecticut employers with 100 or more employees will need to create an employee-facing guide for their overtime and most commonly used pay differential codes, which needs to be published in English, Spanish and the other most common languages spoken by employees. The guides also need to include contact information for a designated office or individual whom employees can contact for any disputes regarding how their pay was calculated. Generally, the guide should include at least 10 pay codes, but there is no obligation to establish new pay codes in order to be in compliance with the new law.

Publishing and Distributing Pay Code Guides

While there is also no obligation to create a website if an employer does not already have one, employers with a website will be required to post the guide on their website (in English, Spanish, and the other most common languages spoken by employees) and provide the URL to employees upon hire. The website address to the guide should also be included on each record of hours furnished to employees. Alternatively, employers can provide a written copy of the guide to employees upon hire in English and the primary language of the employee.  

Expanded Wage Range and Benefits Disclosures in Job Postings

Connecticut will also be expanding transparency requirements in other labor aspects. Effective Oct. 1, all employers are required to not only disclose wage ranges to an applicant once an offer of employment is made, but also provide wage ranges in all internal or public job advertisements. The wage range must be set in good faith for that particular position, and the advertisement must additionally include benefits (insurance, retirement, fringe, leave, etc.) that will be offered with the position. The rule would apply to any position that is performed within Connecticut but also to an employee who works outside of the state but reports directly to a supervisor, office, or worksite in Connecticut. By passing the Act, Connecticut joins the vast majority of the Northeast states that have implemented wage transparency laws, including Maine, Vermont, Massachusetts, New Hampshire, Rhode Island, New Jersey, Delaware and Virginia, as well as other states across the country such as Michigan, Illinois, Minnesota, Nebraska, Colorado, Nevada and the entire West Coast.

Additional Employer Obligations Taking Effect in 2026

The Act includes other new obligations that employers should also be preparing for by Oct. 1, 2026, such as expanded restrictions on employment promissory notes, changes to minimum wage requirements in the cannabis industry, newly required reasonable accommodation rights notices and changing obligations for lactation breaks, among others. If you need help navigating the new pay code or job posting requirements or have questions about other employer obligations that are arising under Connecticut and other state laws, please reach out to your Polsinelli labor and employment attorney.