Pay transparency moved from voluntary practice to statutory requirement in many markets between 2021 and 2026. The specifics matter — what must be published, when, and to whom — and they vary widely.
European Union
In force from June 2026
The EU Pay Transparency Directive (2023/970) requires employers in all 27 member states to disclose pay ranges in job adverts or before the first interview, prohibit asking candidates about salary history, and report gender pay gap data above defined workforce thresholds. Pay gap reporting begins for companies with 250+ employees from June 2027. Companies must take corrective action if the unexplained pay gap exceeds 5%.
Source: EUR-Lex 32023L0970 · National transposition deadlines vary
United States — state by state
Live in 10+ states
No federal pay transparency statute. Pay range disclosure in job adverts is now required in California, Colorado, Connecticut, Hawaii, Illinois, Maryland, Minnesota, Nevada, New York, Washington, and the District of Columbia, with similar laws active or pending in further states. Requirements vary — California and Washington require the range, Colorado requires range plus benefits, New York City requires “good faith” ranges. Salary history bans are now active in roughly half of US states.
Source: state department of labour filings · consult employment counsel by state
United Kingdom
Gender pay gap reporting in force
The UK requires gender pay gap reporting for employers with 250+ employees and is consulting on broader pay transparency rules likely to take effect 2026–27. No general pay range disclosure requirement yet, but voluntary disclosure has become near-standard in financial services and tech sectors. Salary history questions are increasingly discouraged in guidance, though not banned outright.
Source: gov.uk — Gender pay gap reporting
Australia
In force since December 2022
Australia’s Workplace Gender Equality Amendment Act 2022 prohibits pay secrecy clauses in employment contracts and gives employees the right to discuss their pay. Employers with 100+ employees must report gender pay gap data to the Workplace Gender Equality Agency, with company-level data now published publicly since February 2024. No range-in-advert requirement at federal level.
Source: Workplace Gender Equality Agency
India
No statutory requirement
India has no statutory pay transparency law. Range disclosure in job adverts remains voluntary. However, the Digital Personal Data Protection Act, 2023 reshapes how compensation data can be collected, processed, and stored internally — particularly within GCCs that handle employee data on behalf of overseas parents. The Code on Wages, 2019 includes equal pay provisions but doesn’t mandate transparency.
Source: Ministry of Electronics & IT · Code on Wages, 2019
Singapore & rest of APAC
Mostly voluntary
Singapore, Hong Kong, and most of South-East Asia have no statutory pay transparency requirement. Japan’s 2022 amendment to the Act on the Promotion of Female Participation requires employers with 301+ employees to disclose gender pay gap data. South Korea is consulting on similar measures. Voluntary range disclosure is rising in tech and finance hiring across the region but remains the exception.
Source: regional employment law filings