Vermont Pay Transparency Law: The 2026 Employer Guide

Vermont Pay Transparency Law: The 2026 Employer Guide

If you advertise a Vermont job, the posting now has to name a number. Since July 1, 2025, Vermont's Act 155 has required employers with five or more employees to disclose the compensation — or a compensation range — they expect to pay for a role at the moment they write the ad. The rule reaches internal emails, external job boards, and remote listings aimed at Vermont-based workers. It is narrower than California's or Maryland's laws in some ways and broader in others, and the differences are exactly where compliance goes wrong.

This guide walks you through who Act 155 covers, what a compliant Vermont posting must contain, the special rules for commissioned and tipped roles, how the state enforces the law, and how to set ranges you can actually defend. If you run compensation or talent and you hire anyone who works in Vermont, treat this as your working checklist.

TL;DR: Vermont pay transparency at a glance

• Act 155 (H.704) took effect July 1, 2025 and applies to employers with five or more employees, at least one of whom works in Vermont.
• Every written advertisement for a specific Vermont job opening must state the expected compensation or range — the good-faith minimum and maximum salary or hourly wage at the time you create the ad.
• Coverage includes remote roles predominantly performed at a Vermont work location, plus internal postings and third-party listings.
• Commissioned jobs only need to state that pay is commission-based; tipped jobs must disclose that fact plus the range of base wages.
• Oral ads (radio, TV) and vague "We're hiring" notices are not covered.
• The Vermont Attorney General's Civil Rights Unit enforces the law. There is no private right of action — individuals cannot sue directly.
• Act 155 protects workers from retaliation for exercising their rights under the law.

Who the Vermont pay transparency law covers

Start with the headcount test, because it decides whether the law touches you at all. Act 155 applies to any employer with at least five employees where at least one of those employees works in Vermont. Count your whole workforce, not just your Vermont staff — a company with four people in Boston and one in Burlington clears the five-employee threshold and is covered.

Coverage then turns on where the work happens, not where your company is headquartered. The law reaches a job advertisement when the opening is either physically located in Vermont or is a remote role calling for work "predominantly performed" at a Vermont office or other Vermont work location. The Vermont Attorney General's official guidance on Act 155 draws two practical edges here:

• Remote roles can count. If you advertise a remote position and the work will mostly be done from a Vermont location, the posting is covered even if your company sits in another state.
• Occasional Vermont contact does not. A job based elsewhere that only sometimes brings someone into Vermont is not "predominantly performed" in the state, so it falls outside the rule.

The definition of advertisement is deliberately wide. It means written notice, in any format, of a specific covered job opening made available to potential applicants. That includes an internal email to your own workforce inviting applications for a Vermont role. If a staffing agency, recruiter, or job board posts the opening on your behalf, the disclosure obligation still rides with the job. The rule follows the position, not the channel.

What a compliant Vermont job posting must include

For a standard salaried or hourly role, Act 155 asks for one thing done well: the expected compensation or range of compensation. The law defines that range as the minimum and maximum annual salary or hourly wage that you, acting in good faith, expect to pay for the advertised job at the time you create the ad.

Two words carry the weight — "good faith." Vermont is not asking you to predict the exact number a hire will accept after negotiation. It is asking you to publish the honest window you genuinely expect to pay when you write the posting. A range of "$45,000 to $95,000" on a role you actually budget at $60,000 to $70,000 is not a good-faith range; it is a loophole, and it is the pattern enforcement agencies in every transparency state watch for first.

Act 155 does not limit your ability to negotiate. You and a candidate remain free to settle on pay based on qualifications, competing offers, or labor-market factors outside your control. The law simply fixes the starting point: disclose the range you expect up front, then let the conversation proceed from there.

Before you publish a single Vermont range, make sure it rests on real internal logic rather than a recruiter's gut feel. A defensible range comes from a structured pay framework — bands built on job evaluation, not numbers reverse-engineered to look reasonable. Our guide to defensible pay ranges shows how to build ranges that survive scrutiny, and our primer on salary bands covers the structure underneath them.

Special rules: commissioned and tipped roles

Two categories get their own treatment, and both trip up employers who apply the general range rule mechanically.

Commissioned jobs. If a role is paid entirely or partly on commission, the advertisement only has to state that fact. You do not have to publish a compensation figure or range. "This is a commission-based sales role" satisfies the law. You can add a target or draw if you want, but Act 155 does not require it.

Tipped jobs. Tipped roles carry a two-part obligation. The ad must disclose that the position is tipped and state the range of base wages — the non-tip wages you provide — that you expect to pay in good faith at the time you write the ad. In other words, you cannot hide behind expected tips; the employer-paid portion still needs a range.

Getting these two right matters because they are easy to over- and under-comply with. Employers sometimes bury a commissioned role in a full salary range they never intended to honor, or they post a tipped role with no base-wage figure at all. Match the disclosure to the pay structure and you stay clean.

What is not covered

Act 155 has clear boundaries, and knowing them keeps you from over-engineering every recruiting touchpoint. The law does not cover:

• Oral advertisements, even over radio, television, or other electronic media. A spoken radio spot for a Vermont job does not need a range.
• General notices of employment that do not describe a specific opening — think "Help Wanted," "We're Hiring," or "Join Our Team." Once the notice names a specific role, though, it becomes a covered advertisement.
• Jobs performed outside Vermont, including remote roles that will be predominantly performed somewhere other than a Vermont location.

These carve-outs are narrow. The moment a written notice describes an identifiable Vermont opening, you are back inside the rule — so do not lean on them as a compliance strategy.

How Vermont enforces Act 155

Enforcement is centralized, and this is one of the biggest differences between Vermont and states with statutory fines or lawsuits. For nearly all covered employers, Act 155 is enforced exclusively by the Vermont Attorney General, specifically the Civil Rights Unit (CRU) that already handles the state's equal-pay and fair-employment work. The one exception: where the State of Vermont itself is the employer, the Vermont Human Rights Commission has enforcement authority instead.

Critically, Act 155 does not create a private right of action. An individual cannot take an employer to court directly for a missing pay range. Instead, applicants and workers who believe an employer failed to comply are directed to contact the CRU. That does not make the law toothless — the Attorney General can investigate and pursue remedies — but it does mean your compliance risk runs through a state regulator, not a plaintiff's bar. Practically, that puts a premium on consistent, documented practice: an agency reviewing a pattern of non-compliant postings is a very different exposure than a one-off complaint.

Act 155 also includes anti-retaliation protection. You cannot refuse to interview, hire, promote, or otherwise penalize a current or prospective employee because they reported a suspected violation to the Attorney General or the Human Rights Commission. Retaliation is its own violation, separate from the underlying disclosure failure.

Vermont in the wider 2026 patchwork

Vermont rarely stands alone on your compliance map. If you hire across state lines, a single national job posting can trip several laws at once — and each state defines "range," "covered employer," and "posting" a little differently. Maryland sets no size threshold and demands benefits in the ad; New York and Massachusetts run their own tests. Vermont's five-employee floor and its narrow oral-ad and commission carve-outs are Vermont-specific.

The cleanest approach is to build each posting to satisfy the strictest jurisdiction it touches, then confirm it clears the others. We keep the full state-by-state breakdown current in our 2026 multi-state pay transparency compliance guide; the Massachusetts and New York guides are worth a read if you hire in New England or the Northeast alongside Vermont.

How to build Vermont-ready ranges you can defend

A posting rule is really a pay-structure rule wearing a compliance costume. The employers who struggle with transparency laws are the ones publishing numbers they can't explain; the ones who breeze through already have a defensible internal structure. Here is the short version of getting there.

Anchor ranges to job evaluation, not job titles. Two "Analyst II" roles can differ sharply in skill, effort, responsibility, and working conditions. A quantitative point-factor method scores each job against weighted compensable factors, which gives every range an objective spine you can point to if the Attorney General ever asks how you set it.

Document the good-faith basis. When you publish "$68,000 to $82,000," keep a one-line record of why: the pay scale, the budgeted amount, or the actual range paid to comparable employees. That note is what turns a good-faith claim into a defensible one.

Run a pay-equity check before you post, not after. Transparent ranges expose internal inconsistencies to every applicant and employee who reads them. A quick pay equity audit catches gaps between your posted ranges and what you actually pay incumbents — the exact mismatch that invites complaints once pay is out in the open.

Do these three things and Vermont compliance stops being a scramble at posting time. The range is already sitting in your structure, ready to publish.

Frequently asked questions

When did Vermont's pay transparency law take effect? Act 155 (H.704) was signed on June 4, 2024, and took effect on July 1, 2025. Every covered written job advertisement created on or after that date must include the required compensation disclosure.

Which employers have to comply? Any employer with five or more employees, as long as at least one employee works in Vermont. You count your total workforce, so out-of-state companies with a single Vermont-based worker can be covered.

Do remote jobs need a pay range under Act 155? Yes, if the remote role's work will be predominantly performed at a Vermont office or other Vermont work location. Remote roles that will mostly be performed outside Vermont are not covered.

What exactly must a Vermont job posting say? For standard roles, the good-faith minimum and maximum salary or hourly wage you expect to pay at the time you create the ad. Commission roles only need to state that pay is commission-based. Tipped roles must disclose that they are tipped and give the range of base (non-tip) wages.

Are internal job postings covered? Yes. An internal written notice — including an email to your own employees — advertising a specific Vermont opening is a covered advertisement and needs the same disclosure as an external post.

Can an employee sue for a missing pay range? No. Act 155 does not provide a private right of action. Enforcement runs through the Vermont Attorney General's Civil Rights Unit (or the Human Rights Commission when the State of Vermont is the employer). Workers who suspect a violation should contact those offices.

Does posting a range lock in what I can pay? No. Act 155 does not limit negotiation. You disclose the range you expect in good faith when you write the ad, and you and the candidate can still negotiate final pay based on qualifications and market factors.

Vermont's law rewards employers who already know what each job is worth. If your ranges come from a defensible, factor-based evaluation, the number practically writes itself — and it holds up whether an applicant or a regulator asks how you got there. See how PointFactors builds AI-powered, point-factor job evaluations that give every posted range an objective foundation, in Vermont and every other state you hire in.

Justin Hampton is the founder and CEO of PointFactors.