D.C. pay transparency law: ranges, the healthcare disclosure and fines

Since June 30, 2024, any employer with at least one employee in the District of Columbia has had to state the minimum and maximum projected salary or hourly pay in every job listing and advertised position description, and to tell candidates whether healthcare benefits are offered before the first interview. The fines escalate quickly, to $20,000 per violation from the third, and there is no small-employer exception. The healthcare disclosure is the part most multi-state employers forget, because no neighboring state requires it in the same way.

The law and its dates

The requirements come from the Wage Transparency Omnibus Amendment Act of 2023, D.C. Law 25-138, which amended the District's existing Wage Transparency Act of 2014. The amendment became law on March 5, 2024, and section 3 of the act says it "shall apply as of June 30, 2024." It is codified in chapter 14A of title 32 of the D.C. Code, sections 32-1451 through 32-1456.

Who is covered

Section 32-1451 defines an employer as "an individual, firm, association, or corporation that employs at least one employee in the District," excluding the District government and the federal government. There is no headcount threshold. A national company with one remote employee living and working in the District is a covered employer.

Federal contractors are not excluded by that definition. Only the federal government itself is, which matters in a city where much private hiring supports federal agencies.

What every job listing must include

Under § 32-1453.01(a)(1), an employer shall "provide the minimum and maximum projected salary or hourly pay in all job listings and position descriptions advertised." The range "shall extend from the lowest to the highest salary or hourly pay that the employer in good faith believes at the time of the posting it would pay for the advertised job, promotion, or transfer opportunity."

• Both ends are required. "Minimum and maximum" rules out "up to" or "starting at" wording.
• Promotions and transfers are covered. The statute names them, so an internal posting needs the range as well.
• Pay, not benefits. The listing requirement is about salary or hourly pay. Benefits are handled by the separate healthcare disclosure below.

If an employer fails to provide the required disclosures, § 32-1453.01(b) says a prospective employee "may inquire about such disclosures." That is not a substitute for compliance; it confirms that a candidate is entitled to ask.

The healthcare benefits disclosure

Section 32-1453.01(a)(2) requires the employer to "disclose to prospective employees the existence of healthcare benefits that employees may receive before the first interview." The statute does not require plan details, premiums or eligibility rules, only whether healthcare benefits exist. It also does not specify the format.

The easiest compliant approaches are a single line in the job listing ("This role is eligible for medical, dental and vision coverage") or a line in the interview confirmation email. Either way, make it happen before the first interview, and remember that a recruiter phone screen may count as that first interview. If your process starts with a screen, add the line to your phone screen opening or the scheduling message that precedes it.

Pay history and pay discussions

Section 32-1452 prohibits an employer from screening prospective employees based on wage history, including requiring that wage history meet a minimum or maximum, or requiring disclosure of wage history as a condition of being interviewed or staying in consideration. It also bars seeking a candidate's wage history from a previous employer. "Wage history" means compensation received from other or previous employment.

The same section protects employees who ask about, disclose, compare or discuss their own or a colleague's pay. An employer may restrict employees with regular access to others' pay information, such as human resources staff, from sharing it, with exceptions for investigations and legal obligations. Asking about expectations rather than history is the safe approach; see salary expectation questions.

The workplace notice

Section 32-1453.02 requires an employer to post a notice of employees' rights under the chapter "in a conspicuous place in at least one location where employees congregate." For an employer whose only D.C. employee is remote, the statute does not say how to meet a physical posting requirement; electronic delivery is the common practical answer, but we did not find official guidance confirming it.

Remote roles

The statute does not address remote positions directly. Coverage is triggered by the employer having at least one employee in the District, and the listing duty applies to "all job listings." Read literally, a covered employer's listings are covered whether or not the advertised role is in D.C. At a minimum, any role performed in the District and any remote role open to District residents should carry a range.

Penalties and enforcement

Under § 32-1455, the Mayor assesses the fines through the District's administrative adjudication process. The Attorney General may also investigate, issue subpoenas, and bring a civil action for restitution or injunctive, compensatory or other relief, and on prevailing is entitled to attorney's fees and costs and statutory penalties equal to the administrative ones. The section states that nothing in the chapter "shall be construed to create a private right of action." The fines are fixed amounts, not ranges, and the statute does not say whether one listing on several sites counts as one violation or several.

What it means for agencies and recruiters

The District's statute regulates employers; it does not separately name employment agencies the way New York or Nevada do. But an agency advertising a covered employer's role is publishing that employer's job listing, and the listing duty covers "all job listings and position descriptions advertised." The fine lands on the employer, which will not distinguish between its own careers page and an agency's post. Agencies placing candidates with D.C. employers should:

• require a minimum and maximum from the client before posting;
• confirm whether the client offers healthcare benefits, and say so in the ad or before the first screen;
• avoid any question about a candidate's current or past pay, including in intake forms and submittal templates; and
• keep a copy of each ad as published, since an investigation may ask what a listing said on a given day.

Common mistakes

• "Salary commensurate with experience." No numbers means no compliance.
• Healthcare mentioned only at the offer stage. The statute requires it before the first interview.
• Assuming small employers are exempt. One employee in the District is enough.
• Internal postings without a range. Promotion and transfer opportunities are named in the statute.

One posting for D.C., Maryland and Virginia

Many employers hire across the region with one ad. Maryland requires a wage range plus general benefits and other compensation; see the Maryland guide. Virginia requires a wage, salary or range in every public and internal posting from July 1, 2026; see the Virginia guide. A posting with a good-faith minimum and maximum, a short benefits paragraph that mentions healthcare, and a bonus or commission line satisfies all three at once.

A District of Columbia checklist

DISTRICT OF COLUMBIA CHECKLIST (D.C. Code § 32-1451 et seq.)

[ ] At least one employee in D.C. (not the D.C. or federal government)
[ ] Every listing and advertised position description shows a minimum
    AND maximum projected salary or hourly pay
[ ] Range runs from the lowest to highest pay you would in good faith
    offer, including for promotions and transfers
[ ] Candidates told whether healthcare benefits exist BEFORE the first
    interview (listing, confirmation email or screen script)
[ ] No wage-history screening; no wage-history requests to past employers
[ ] Rights notice posted where employees congregate

For the full comparison of states and the District, see pay transparency laws by state.