Minnesota Job Postings Must Comply With New Compensation Disclosure Requirements Beginning January 2025

The final days of the 2024 Minnesota legislative session brought a flurry of activity impacting Minnesota employment laws, including many substantive changes to existing Minnesota employment laws and several new employment laws. One of the new laws is Minnesota Statutes section 181.173, requiring employers with at least 30 employees to include pay rate and benefits information in job postings and solicitations.

Effective Jan. 1, 2025, any “person or entity that employs 30 or more employees at one or more sites in Minnesota” must disclose in each posting for each job opening “the starting salary range” and “a general description of all the benefits and other compensation, including but not limited to any health or retirement benefits,” that will be offered to the applicant hired for the position. With regard to the salary range, this means that each posting must include “the minimum and maximum annual salary or hourly range of compensation” for that job opportunity with the employer at the time it posts the job. The salary range can be based on the employer’s good faith estimate, but cannot include an open-ended range. Further, if an employer does not plan to offer a salary range for the position posted, the posting “must list a fixed pay rate.”

The scope of this disclosure requirement is broad. An employer must include the wage disclosure information in any solicitation posted electronically or in hard copy that includes qualifications for desired applicants and is intended to recruit job applicants for a specific available position. The requirement also applies to the employer regardless of whether it is doing the recruiting directly or through a third party.