Massachusetts Becomes 11th State to Adopt a Pay Transparency Law

August 7, 2024

On July 31, 2024, Massachusetts became the 11th state to adopt a pay transparency act when Governor Maura Healy signed “An Act Relative to Salary Range Transparency" into law. This law will take effect on July 31, 2025 with a portion of it beginning February 1, 2025.


Under this law, Massachusetts employers with 25 or more employees will be required to include salary range information on all job postings and provide this information to both applicants and current employees regarding their positions. Additionally, employers with more than 100 employees will need to disclose demographic and pay data to the Commonwealth by filing an annual wage report, known as an aggregate wage data report, with the state Executive Office of Labor and Workforce Development. Although these reports will not be public record, the Commonwealth will compile the data into an aggregate report, broken down by industry, which will be posted on the Department of Labor and Workforce Development’s website no later than July 1 each year, starting in 2025.


The purpose of this law is to promote pay transparency and protect workers’ rights by ensuring they have access to salary range information, whether they are applying for a new position, seeking a promotion, or facing a transfer within their current organization.


Key Dates to Remember

Employers must implement two key practices:

1.     By February 1, 2025, employers with 100 or more employees must submit their pay data to the Commonwealth.

2.     By July 31, 2025, all employers with 25 employees or more must ensure that salary or wage information is included in all job postings. Failure to comply may result in fines or citations.


Prepare Early

Although the effective dates may seem distant, it is crucial to prepare in advance. Employers should establish pay ranges for each position and integrate these ranges into job postings as a standard practice. To proactively address potential issues, employers should also consider conducting a pay equity audit to identify and address any existing pay disparities that could impact the business.   


Employers should consult with their employment counsel to develop a plan to avoid fines or citations. The Attorney General will have the authority to enforce this law through fines and/or civil citations. Initial violations will be subject to warnings, with subsequent offenses incurring fines ranging from $500 to $25,000 for a fourth or any subsequent offenses.


If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.

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Remote Workers and the WARN Act

July 9, 2025
Background: The e-commerce website Zulily liquidated in May 2023 and laid off its entire workforce by the end of 2023. While in-person workers at Zulily’s Seattle headquarters and fulfillment centers in Ohio and Nevada received 60 days’ notice or pay under the Worker Adjustment and Retraining Notification (WARN) Act, remote employees were not given any notice or pay. Four remote workers—two based in Washington and two based in Ohio—filed a class action lawsuit claiming that this was a violation of the WARN Act and state wage laws. The workers argued that because their roles were assigned to corporate offices or fulfillment centers, they should have been considered “affected employees” under the WARN Act when those sites closed. In a decision that could signal a significant shift in how the WARN Act applies to remote workers, the federal judge refused to dismiss the workers’ claims.  Key Legal Questions 1. Do Remote Workers Qualify for WARN Act Protections? The core of the dispute centers on whether remote workers can be considered part of a “single site of employment” that closed or experienced a mass layoff—terms that define whether the WARN Act’s notice requirements kick in. 2. Are WARN Act Damages Considered “Wages”? The Plaintiffs also brought state wage claims, arguing that the pay they would have received with proper WARN Act notice should be considered unpaid “wages” under Washington law and Ohio law. What the Court Decided: Judge Kymberly K. Evanson rejected the company’s motion to dismiss the case. Finding that Zulily’s argument that remote employees do not work at a single site with 50 or more workers and thus aren’t covered, was a factual question not suitable for early dismissal. Prior cases support the idea that even home-based employees may be “affected employees” if tied to a central worksite that shuts down. The court also found that if the WARN Act applies, then the Plaintiffs could plausibly claim that Zulily withheld “wages” owed under Washington and Ohio laws —opening the door to potential double damages and attorney fees. The Plaintiffs haven’t won their case; the court’s refusal to dismiss the claims allows them to move forward to discovery and potentially class certification. If they succeed, the case could set a precedent requiring companies to treat remote employees as part of larger employment sites for WARN Act purposes. With remote work here to stay, courts—and employers—will need to grapple with what "site of employment" really means in the 21st-century workforce. For employers, the message is clear: remote doesn't mean exempt. As the legal framework catches up with modern work arrangements, companies must tread carefully when making large-scale employment decisions. If your business has any questions on this topic or any other matters, please do not hesitate to contact the attorneys at The Royal Law Firm at 413-586-2288.