Compliance with District of Columbia’s Comprehensive Pay Transparency Law Begins June 30, 2024

The District of Columbia successfully amended its wage transparency laws, bringing employers a June 30, 2024, compliance date for the new pay and benefit transparency obligations.

The District of Columbia passed the Wage Transparency Omnibus Amendment Act of 2023, changing its 2014 wage transparency laws to provide applicants and employees expanded pay protections while being screened in a hiring, promotion, or transfer process.

Becoming Law

The District of Columbia Council voted to enact the new law on Dec. 19, 2023. After passing both Mayoral and Congressional review, the law became effective on March 5, 2024.

The law applies to any employer with at least one employee in the District of Columbia. Thus, employers must be vigilant as to the location of any prospective job, promotion, or transfer opportunities (including remote positions or workers) to understand what is required.

Legal Requirements for Employers

District of Columbia employers must:

1. Provide the minimum and maximum projected salary or hourly rate in all job listings and position descriptions; 
    
2. Disclose to applicants before the first interview the healthcare benefits an employee may receive; 
    
3. Refrain from seeking the prospective employee’s wage history, including from a person who previously employed the individual; and
    
4. Post a notice in a “conspicuous” place informing employees of their rights under the Wage Transparency Omnibus Amendment Act of 2023.

Keep in mind that these requirements would also affect postings for PERM green card cases.

While the District of Columbia Office of Human Rights may create a sample notice at some point, at the time of this writing, none has been provided. Employers can create their own or use our sample notice to meet the posting requirements.

Please contact the authors or any Jackson Lewis attorney if you have any questions.

(Summer Associate Nina Bundy contributed to this article.)