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Cleveland Joins the Pay Transparency Movement: What Employers Need to Know

Client Alert
October 21, 2025

Beginning October 27, 2025, all Cleveland employers with 15 or more employees will be prohibited from asking applicants about their pay history and will be required to include reasonable pay ranges in all job postings where the position will be performed, solicited, considered, or processed in Cleveland. The ordinance is intended to help close the gender wage gap and promote greater pay equity across the city.

Overview of the New Cleveland Law

On April 28, 2025, the Cleveland City Council passed Ordinance No. 104-2025, which requires employers to include pay ranges in job notifications, advertisements, or other formal job postings that could reach applicants within or outside Cleveland for potential employment in the city. These posted pay ranges must be a reasonable, good-faith estimate of what the employer expects to pay for that specific position when filled.

Pay Transparency Requirements

Employers may not request, require, or rely on an applicant’s pay history or allow it to affect their screening or hiring decisions in any way. If an employer inadvertently receives pay information, they must not rely on it when deciding whether to offer the position or when determining the rate of pay for the applicant.

Exceptions to the Law

This law will not apply in the following circumstances:

  1. When an employee is transferred or promoted internally;
  2. When an applicant voluntarily discloses their pay history during the application process, without being asked;
  3. When pay history is discovered during a background check (note, employers still may not rely on this information during the screening or hiring process);
  4. When a former employee is rehired and the employer already has the applicant’s pay history on file; or
  5. When another law specifically authorizes the employer to rely on the applicant’s pay history.

Action Steps for Employers

Employers are guided to consider the following actions to help comply with the Ordinance. First, they should review and update all current job notifications, advertisements, and other formal job postings to include a good-faith estimate of a position’s pay range. Next, employers should train hiring managers and recruiters to ensure they do not ask about or rely on applicant’s pay history during the hiring process. Finally, employers should remove all salary history questions from job applications, interviewing materials, and any pre-screening tools to maintain compliance with the ordinance and promote fair hiring practices.

Pay Transparency Movement

The Cleveland pay transparency law follows a growing trend across Ohio aimed at promoting fair and equitable hiring practices. Several other cities have already enacted similar measures, including Cincinnati in March 2020 (Ordinance No. 83), Toledo in June 2020 (Pay Equity Act), and Columbus in March 2024 (Ordinance 0709-2023). While Cleveland has not yet gone as far as other jurisdictions, it may eventually take a similar approach to Colorado, which has become a national leader in pay transparency. In 2024, the Colorado Department of Labor and Employment adopted the Interpretive Notice & Formal Opinion (“INFO”) #9A, which requires any employer with at least one employee within the state to include, in good faith, a reasonable pay range in every job posting. Cleveland’s new law could represent an early step towards adopting a similar comprehensive transparency standard in the future.

Conclusion

As it stands, Cleveland employers, with 15 or more employees, should begin implementing these changes by updating their hiring practices to ensure full compliance with Ordinance No. 104-2025. Consulting with legal counsel before making policy changes can help mitigate risks and ensure compliance with applicable laws.

For further guidance on how pay transparency requirements may impact your employment policies, please contact our team today. Bryan Meek is a Partner at Brennan, Manna & Diamond, LLC and is the Co-chair of its Labor & Employment Division. Bryan may be contacted at 330-253-5586 or via email at bmeek@bmdllc.com.

Employment LawEmployment and Labor LawBryan MeekAdrianna GlobokarWage GapPay Transparency
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