Update Applicable to:	Effective Date
All Covered Entities with 15 or More Persons in The City of Cleveland	180 Days After Signature October 27, 2025

What happened?
On April 28, 2025, Cleveland, Ohio, enacted Ordinance 104-2025 (Pay Transparency), in which Cleveland employers will need to include salary ranges in job postings and refrain from asking job applicants questions related to their salary history. It is pending the mayor’s signature.

Overview:
The ordinance introduces several critical requirements for employers operating within Cleveland’s geographic boundaries:

1. Mandatory Salary Disclosure:

Employers must include a salary range or scale in all job postings, advertisements, and formal notifications.

• The definition of “salary” is broad, encompassing wages, commissions, hourly earnings, bonuses, and benefits.

2. Ban on Salary History Inquiries:

To prevent perpetuation of historical wage disparities, the ordinance prohibits employers from:

• Asking about an applicant’s current or prior salary.
• Using salary history to screen candidates or determine compensation.
• Retaliating against applicants who decline to disclose salary history.

Employers may still discuss salary expectations, and applicants may voluntarily disclose their salary history without prompting.

3. Scope and Applicability:

The ordinance applies to:

• Positions performed within Cleveland or for which the application is processed in Cleveland, even if interviews are conducted remotely.
• Private employers with 15 or more employees, including staffing and referral agencies.
• Excludes state, federal, and other local government entities (except the City of Cleveland itself).

4. Exemptions:

Certain roles and situations are exempt from the ordinance:

• Internal promotions or transfers.
• Rehires where salary history is already known.
• Independent contractors.
• Positions governed by collective bargaining agreements.

5. Enforcement and Penalties:

The Fair Employment Wage Board (FEWB) will oversee enforcement. Individuals may file complaints within 180 days of an alleged violation. Employers found in violation will have 90 days to correct the issue before penalties are imposed.

• Civil penalties include:
• $1,000 for a first violation
• $2,500 for a second violation
• $5,000 for a third violation within five years.

These amounts will be adjusted annually based on the Consumer Price Index (CPI-U).

6. Action Steps for Employers:

To prepare for compliance, employers should begin taking the following steps:

• Update Job Postings: Ensure all listings include accurate salary ranges.
• Revise Hiring Processes: Eliminate salary history questions from applications and interviews.
• Train HR Teams: Educate recruiters and managers on the new rules and how to manage voluntary disclosures.
• Audit Compensation Structures: Review pay practices to ensure internal equity and alignment with the ordinance.

Source References

• OH – Cleveland City Council Pay Transparency Law Press Release
• Cleveland City Pay Transparency – Ord. No. 105-2025

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