Vermont pay transparency law: ranges in job ads at five employees

Vermont has required pay ranges in job advertisements since July 1, 2025. An employer with five or more employees must include the compensation or range of compensation in any advertisement for a Vermont job opening, including openings that current employees can apply for and remote roles that predominantly work for a Vermont office. The statute is specific about tipped and commission roles and about which announcements are not "advertisements," and it sends all enforcement through the Attorney General.

The statute

The rule is 21 V.S.A. § 495p, "Disclosure of compensation to prospective employees," added by Act 155 of the 2024 adjourned session and effective July 1, 2025. It sits in Vermont's fair employment practices subchapter, next to the state's salary history ban in § 495m. Note the letter: § 495o is a different law, about employer meetings on religious or political matters, and is sometimes cited by mistake for the pay rule.

Who is covered

The section defines "employer" as an employer under § 495d "that employs five or more employees." The statute does not say where those five must work. Five is a low bar: it reaches most small businesses that advertise openings at all.

Which job openings count

The duty applies to an advertisement of a "Vermont job opening," defined as a position that is either:

• physically located in Vermont, or
• a remote position that will predominantly perform work for an office or work location that is physically located in Vermont.

It also has to be a position the employer is hiring for, which the statute says includes positions open to internal candidates, external candidates or both, and positions into which current employees can transfer or be promoted. A position physically outside Vermont that works predominantly for offices outside Vermont is expressly excluded.

That makes the remote test about where the work is directed, not where the employee lives. A Burlington company's fully remote role filled by someone in Colorado is a Vermont job opening. A New York company's remote role filled by someone living in Vermont, working for the New York office, is not, at least under Vermont's definition; Colorado's or New York's own law may still apply.

Because internal and promotional openings are covered, your internal job posting template needs a pay line for Vermont roles.

What counts as an advertisement

An "advertisement" is a written notice, in any format, of a specific job opening made available to potential applicants, and "potential applicants" includes both current employees and the public. Two things are excluded:

• general announcements that employment opportunities may exist, without identifying a specific job opening; and
• verbal announcements made in person or on radio, television or other electronic media.

A radio spot saying "we're hiring drivers" does not need a range. The written job post the radio spot sends people to does.

What the advertisement must say

"Good faith" is defined as "honesty in fact." The statute also says nothing in it prevents hiring above or below the advertised range "based on circumstances outside of the employer's control, such as an applicant's qualifications or labor market factors." That is a useful line: the range is an honest expectation at the time of posting, not a ceiling the employer can never exceed.

Vermont does not require benefits, bonus details or an application deadline in the advertisement.

Retaliation

It is a violation of § 495p, and of the general retaliation provision in § 495(a)(8), for an employer "to refuse to interview, hire, promote, or employ a current or prospective employee for asserting or exercising any rights" under the section. A candidate who asks why an ad lacks a range, or asks for it, is asserting those rights.

Enforcement and penalties

Subsection (b)(1) says the section, and any retaliation claim for exercising rights under it, "shall only be enforced" under 21 V.S.A. § 495b(a)(1). That subsection lets the Attorney General or a State's Attorney restrain prohibited acts, seek civil penalties, obtain assurances of discontinuance and conduct civil investigations using the procedures of Vermont's consumer protection law, 9 V.S.A. §§ 2458 to 2461. Under 9 V.S.A. § 2458(b)(1), a court may impose a civil penalty of not more than $10,000 for each violation.

The general private right of action in § 495b(b) is not on that path. The "only" in § 495p(b)(1) points to public enforcement, which means a complaint goes to the Attorney General's office or a State's Attorney rather than straight to court. We did not find a court decision applying that reading as of October 2026.

Salary history and expectation questions

Vermont has banned salary history questions since 2018 under 21 V.S.A. § 495m. An employer may not ask about or seek a prospective employee's current or past compensation, from the candidate or a current or former employer; may not require that past pay meet a minimum or maximum; and may not decide whether to interview someone based on past pay. "Compensation" there includes wages, salary, bonuses, benefits, fringe benefits and equity. If a candidate volunteers it, the employer may confirm it only after making an offer with compensation.

Section 495m(c) also says plainly that the ban does not prevent an employer from "inquiring about a prospective employee's salary expectations or requirements." For phrasing, see salary expectation questions.

What this means for agencies

Section 495p puts the duty on "an employer," which "shall ensure" that the advertisement includes the range. An agency's ad for a client's Vermont opening is still an advertisement of that opening made available to potential applicants, so the client is responsible for it and will expect the agency to get it right. Collect the range, and whether the role is commission-based or tipped, at intake. For remote roles, also ask which office the hire will predominantly work for, because that answer decides whether the opening is a Vermont job opening at all.

Worked examples

• Covered: a Montpelier nonprofit with eight staff advertises a program coordinator role on its website. Five or more employees, physically in Vermont, written ad for a specific opening: the range must be in the ad.
• Covered: a Vermont software company posts a fully remote engineering role that will work for its Burlington team. The remote employee may live anywhere; the role predominantly works for a Vermont office.
• Not covered by Vermont: a Boston firm's remote role, filled by a Vermont resident, working for the Boston office. Massachusetts law may apply instead.
• Commission and base: a sales role paying a base salary plus commission is paid on commission "in part," so the ad may disclose that fact instead of a range.

These are examples to illustrate the definitions, not rulings on any particular employer.

Vermont alongside its neighbors

Vermont's five-employee threshold is far lower than Massachusetts' 25; see the Massachusetts guide. New Hampshire is not among the states we could confirm with a posting requirement as of October 2026, so a regional employer may have different rules for roles a few miles apart. Maine requires ranges at 10 employees, covered in the Maine guide.

A Vermont advertisement checklist

VERMONT JOB ADVERTISEMENT CHECKLIST (21 V.S.A. § 495p, from July 1, 2025)

[ ] Employer has 5 or more employees
[ ] Role is physically in Vermont, OR remote and predominantly works for
    a Vermont office or work location
[ ] Applies to internal, external, transfer and promotion openings
[ ] Written ad for a specific opening (verbal and general "we're
    hiring" notices are excluded)
[ ] Salaried/hourly: minimum and maximum expected in good faith
[ ] Commission (in whole or part): ad says so
[ ] Tipped: ad says so and gives the base wage or base wage range
[ ] No questions about current or past pay; expectations are fine

For the full state comparison, see pay transparency laws by state.