New Jersey continues to tighten its pay transparency requirements. On September 15, 2025, the New Jersey Department of Labor (NJDOL) published proposed rules clarifying how employers must disclose salary ranges and notify employees of job opportunities under the New Jersey Pay Transparency Act, which took effect June 1, 2025. Although these rules are not yet final, they offer a preview of what enforcement may look like—and signal the need for HR teams to start preparing now.
Key Highlights of the Proposed Rules
1. Employer Coverage
The proposed rules define a covered employer as any organization with:
- At least 10 employees over 20 calendar weeks (inside or outside New Jersey), and
- Operations that do business, employ persons, or accept job applications within New Jersey.
To fall under the law, both the job solicitation and physical work location must be in New Jersey.
2. Pay Range and Benefits Disclosure
When advertising for new roles, promotions, or transfer opportunities, employers must include:
- A minimum and maximum pay range; and
- A general description of benefits such as health, life, or disability insurance, paid time off, training, and pension plans.
If you advertise a pay range instead of a single rate, the spread cannot exceed 60% of the minimum salary or hourly rate—unless the range is set by a union contract or statute.
Forework Tip: Audit your job postings and templates to ensure you can quickly integrate transparent pay ranges and benefit summaries.
3. Internal Notification of Promotions
Employers must make “reasonable efforts” to notify employees of promotion opportunities by:
- Posting notices in visible, accessible locations in the relevant departments; and
- Posting on the company intranet or internal website if one exists and is accessible to all employees.
4. Third-Party Job Boards
Employers are only responsible for postings on third-party sites if they control or approve the advertisement content. This means if a vendor posts automatically without your oversight, you likely won’t be cited—though best practice is to verify listings regularly.
Enforcement, Complaints, and Penalties
Violations carry civil penalties similar to those under the state’s Wage and Hour Law.
Employers will receive:
- Written notice of any alleged violation;
- The proposed penalty amount; and
- 15 business days to request a hearing.
Cases may go through an informal conference first; unresolved matters proceed to a formal hearing before a commissioner, with appeal rights to the New Jersey Superior Court.
Next Steps for Employers
Even though these are only proposed rules, proactive preparation is key.
- Review pay structures and job postings for compliance readiness.
- Establish salary ranges for all positions if you haven’t already.
- Ensure third-party recruiters and posting platforms follow the same guidelines.
- Compare requirements across states if you operate in multiple jurisdictions.
Forework Tip: Early alignment avoids disruption to hiring and protects your business from future penalties once the rules become final.
At Forework, we help employers simplify compliance—from wage transparency to payroll logic—by combining legal insight with technology that ensures accuracy and peace of mind.