New Massachusetts Pay Transparency Law Takes Effect October 29, 2025

Employers with 25+ employees must disclose wage ranges. Employers with 100+ employees will also face new workforce reporting requirements.

In July 2024, Governor Maura Healey signed An Act Relative to Salary Range Transparency (also referred to as the Massachusetts pay transparency law). The law is intended to increase wage transparency, narrow pay inequities, and standardize expectations for applicants and current employees. Source: Office of the Governor.

Most employer-facing requirements take effect on October 29, 2025. Source: Massachusetts Attorney General’s Office (AGO).

Key Requirements for Employers With 25+ Employees

If your organization has 25 or more employees whose primary place of work is Massachusetts, you must meet all of the following requirements:

• Pay range in every job posting. You must include the “reasonable in good faith” wage or salary range that you expect to pay for the position, at the time you post it. This applies to internal and external postings, and to postings made by recruiters or third-party services on your behalf.
  AGO Pay Transparency Guidance | Jackson Lewis analysis
• Applicants’ right to the range. Applicants have the legal right to know the pay range for the position they’re applying for, at any stage of hiring, including offer.
  AGO Pay Transparency Guidance
• Current employees’ right to request. Current employees may request the pay range for their own position. Employers must provide it and may not retaliate against employees for asking.
  AGO Pay Transparency Guidance

Additional Requirements for Employers With 100+ Employees

If your organization has 100 or more employees in Massachusetts (and is required to file the federal EEO-1 report), you will also be required to submit that workforce demographic/pay data to the Commonwealth. The state has indicated that it will collect EEO-1 style information by job category, race/ethnicity, and gender identity. Source: Massachusetts Workforce Data Reporting FAQs.

Large agencies in home health, hospice, and private care should be prepared to:

• Identify who in your organization is responsible for EEO-1 reporting today (HR, payroll, compliance, counsel).
• Confirm that demographic and job category data is current and consistent across systems (payroll, scheduling, staffing platforms, etc.).
• Be prepared to provide this data to the Secretary of the Commonwealth / Executive Office of Labor and Workforce Development on request in 2025 and beyond.
  State Workforce Data Reporting FAQs

Enforcement, Penalties, and the “Cure” Period

The Massachusetts Attorney General’s Office is responsible for enforcement. Violations can trigger monetary penalties. However, for the first two years of implementation — through October 29, 2027 — employers will generally have two business days to correct (“cure”) certain defects after being notified by the state.
Ogletree Deakins summary

What This Means for Home Care Agencies

These rules are not limited to hospitals or large systems. They also apply to:

• Private duty / private pay agencies
• Certified home health agencies
• Hospice programs
• Staffing / temp / per diem pools you operate internally

You will need to:

• Add a pay range to all job postings (RN, PT, billing specialist, scheduler, PCA/HHA, etc.).
• Be ready to provide the range on request to any current employee in that role.
• Document how you set each range. “Reasonable and in good faith” means you should be able to explain how you arrived at the minimum and maximum for that role (market data, internal equity, etc.).
• Train hiring managers. Anyone involved in recruiting should understand that pay ranges are now disclosable by law — this is no longer optional.
• For 100+ employee organizations: Align HR and compliance staff now around the EEO-1 style dataset that the state will require.

Recommended Timeline

• Now through Q4 2025: Inventory every active and recurring job posting. Create or update pay ranges for each role you hire. Update offer letter templates and promotion/transfer notice templates.
• By October 29, 2025: Ensure every posted job includes a pay range. Put in place an internal process for responding to employee pay range requests.
• For agencies with 100+ employees: Confirm responsibility for state workforce data reporting and make sure your most recent EEO-1 is clean and current. The state has signaled that this reporting requirement will be ongoing. State Workforce Data Reporting FAQs.
• Ongoing: Monitor postings for compliance, keep pay ranges up to date with market conditions, and maintain documentation to demonstrate “good faith.”

This summary is for general informational purposes for Home Care Alliance members and does not constitute legal advice. Agencies should consult internal counsel or HR compliance advisors for agency-specific guidance.