Joyce Hottinger

In the 2024 Minnesota legislative session, a new law promoting pay transparency was included in the omnibus labor bill. Starting Jan. 1, 2025, the new law will require employers with 30 or more employees to include the starting salary range, a general description of benefits, and details of other compensation (including health and retirement benefits) in any job posting.

This requirement applies to Minnesota employers, including cities, for any electronic or printed job posting. If a city uses a third party for recruitment, like an executive search firm, the starting salary range and general description of benefits is required for those job postings as well.

A “salary range” under the law is defined as the minimum or maximum salary or hourly range of compensation for a job at the time of posting based on an employer’s “good faith estimate,” but the salary range may not be open-ended. If a city does not offer a salary range, the position must list a fixed pay rate.

Minnesota pay transparency goals

This 2025 law continues to build on the state’s employer pay transparency goals. Effective Jan. 1, 2024, Minnesota prohibited employers from asking about or considering job applicants’ past or current pay during the hiring process. The law applies to all job applicants, including current employees seeking an internal promotion or transfer, and full- and part-time employees. While job applicants can voluntarily, without prompting, share past and/or current pay to negotiate higher pay, employers may not request that information.

The new Minnesota requirement that job postings include salary ranges is already in place in other states, including California, Colorado, Connecticut, Hawaii, Illinois, Maryland, Nevada, New York, Washington, and Rhode Island. Colorado was the first state to pass such a law.

Proponents of pay transparency feel that not only does including salary ranges help avoid discrimination, but it can also save time for employers and candidates alike in the recruitment process. For job seekers, including salary ranges can help them decide if the pay range is sufficient for their needs. In a LinkedIn study, 91% of U.S. respondents say that salary ranges affect their decision to apply for a job. In addition to helping attract talent, employers that include pay ranges can save time and stress in job offer negotiations because the salary and benefits have already been laid out.

Complying with the new law

Here are some next steps cities should take to ensure compliance with the 2024 and 2025 Minnesota pay transparency laws:

• Confirm that your employment applications are not requesting previous salary information. The League’s model employment application may be a good starting place if your city has not updated its employment application in a while. Access the LMC model employment application at lmc.org/employmentapp.
• To support pay transparency efforts, employers should know if their pay and salary offers are within the market range. If it has been a while since you reviewed your pay rates and ranges, consider participating in the Local Government Salary & Benefits Survey. Members who update their salary and benefits data by the deadline have free access to survey data. Learn more about the survey at lmc.org/salarysurvey.
• Begin reviewing your job ads to ensure they include the necessary information, like salary ranges and benefits, in order to be in compliance in 2025. The League will be updating its model job ads, so be on the lookout for some model language later in 2024.
• Ensure your hiring teams are aware of the new laws as to avoid asking applicants about previous wages, as well as making sure job postings in 2025 include salary ranges and benefit.

Joyce Hottinger is assistant human resources director with the League of Minnesota Cities. Contact: jhottinger@lmc. org or (651) 281-1216.