Vermont Pay Transparency Law: What Employers Must Know

Governor Phil Scott signed H.704 into law as Act 155 on June 4, 2024, with the posting requirement taking effect July 1, 2025. The Vermont Attorney General issued formal guidance on December 31, 2024, resolving several open questions before enforcement began. Vermont joins the states with active posting laws with a notably low threshold: five employees, counted company-wide, with as little as one working in Vermont.

Quick facts

Law

Act 155 (H.704, 2024)

Signed

June 4, 2024 (Gov. Phil Scott)

Effective date

July 1, 2025

Employer threshold

5 or more employees total, with at least one employee working in Vermont

Required: salary range

Yes — good-faith minimum and maximum annual salary or hourly wage, in written advertisements

Required: benefits

No

Commission-only roles

Must state the role is commission-based; no range required

Tipped roles

Must disclose tipped status plus the base-wage range

Applies to remote roles

Only when work is predominantly performed from a Vermont office or work location

Penalty

No fixed schedule — injunctions, restitution, and civil penalties under 21 V.S.A. § 495b

Enforced by

Vermont Attorney General (Civil Rights Unit); no private right of action

Written advertisements — and what that includes

Act 155 applies to writtenjob advertisements, internal and external — careers pages, job boards, and internal postings for transfers and promotions all count. The range must be a good-faith estimate: the minimum and maximum annual salary or hourly wage the employer expects to pay for the role at the time of the posting. A single number, “competitive pay,” or a range the employer does not actually intend to honor all fall short of the standard.

The law carves out two special cases. Commission-only roles must say they are paid on commission, but need not include a range. Tipped roles must disclose that the position is tipped and include the range of the base wage.

The remote-work boundary

Unlike Colorado’s law, which reaches any posting a Colorado resident could work, Vermont’s coverage is narrower: it applies to jobs physically located in Vermont and to remote roles whose work is predominantly performed from a Vermont office or work location. A role that can be done from anywhere, with no Vermont anchor, is not clearly covered. That said, a nationwide remote posting is likely subject to several other states’ laws simultaneously — the practical answer for multi-state employers is to include a compliant range everywhere.

How enforcement works

There is no per-violation dollar amount to budget against. Violations are enforced as unfair employment practices under 21 V.S.A. § 495b by the Attorney General’s Civil Rights Unit and State’s Attorneys, who can seek injunctions, restitution, civil penalties, and investigative costs. Individuals cannot sue directly — but an AG inquiry is its own cost, and the December 2024 guidance signals the office expects compliance.

Frequently asked questions