On Nov. 18, 2024, New Jersey Gov. Phil Murphy enacted Senate Bill 2310, a law mandating pay transparency in job advertisements and the posting of internal promotional opportunities. The law takes effect on June 1, 2025, and applies to New Jersey employers with 10 or more employees over 20 calendar weeks.
Effective June 1, 2025, covered New Jersey employers must include salary information in job listings and post promotional opportunities.
Pay Transparency Requirements
The new law requires covered employers to disclose in each posting for new jobs and transfer opportunities that are advertised either externally or internally:
· The hourly wage or salary, or range thereof; and
· A general description of benefits and other compensation programs for which the employee would be eligible.
However, temporary help services or consulting firms are not required to provide this information in postings used to identify qualified applicants for potential future job openings that do not yet exist. Also, employers may increase the compensation identified in the posting when an employment offer is made.
Internal Promotion Requirements
Covered employers must make reasonable efforts to announce promotional opportunities to all current employees in the affected department before making a promotional decision unless the decision is based on years of experience or performance. The law does not prohibit employers from making a promotion on an emergent basis due to an unforeseen event.
Penalties
Employers who fail to comply with the new law may be subject to civil penalties of $300 for the first violation and $600for each subsequent violation.
Next Steps for Employers
To comply with the law by its effective date, employers can take steps now, such as establishing a methodology for determining compensation ranges, reviewing and updating job postings, conducting a pay audit to identify and remedy any pay disparities, and ensuring the appropriate parties (such as HR and recruiting personnel) are trained on the requirement to include compensation information in job advertisements and post promotional opportunities internally.
