WHAT YOU NEED TO KNOW
- Cleveland has passed a new law imposing additional restrictions on employers in the hiring process, requiring salaries to be included in job postings and prohibiting inquiry into applicants’ salary history.
- The new law, Ordinance No. 104-2025, codified as Chapter 669 of the Cleveland Codified Ordinances, enters into effect on October 27, 2025.
On April 30, 2025, the Cleveland City Council passed Ordinance No. 104-2025, requiring employers to include salary ranges on job postings and barring inquiries into an applicant’s compensation history. The new law enters effect on Oct. 27, 2025.
Cleveland joins other Ohio cities such as Toledo, Columbus, and Cincinnati, as well as numerous other states and municipalities that have passed similar wage transparency laws.
WHICH EMPLOYERS ARE COVERED?
Generally, the new law applies to any employer with 15 or more employees within the city of Cleveland, or to any position where the work is completed within Cleveland, or where the application is solicited, received, processed, or considered within the city.
These restrictions do not apply to internal transfers or promotions.
COMPENSATION HISTORY PROHIBITIONS
Ordinance No. 104-2025 prevents covered employers from:
- Inquiring into an applicant’s prior compensation history.
- Screening applicants based on their current or prior compensation, including requirements of maximum or minimum past salary.
- Relying upon an applicant’s compensation history to determine an offer of employment or compensation.
- Retaliating against, including through refusing to hire, an applicant who does not disclose their compensation history.
An employer may discuss salary expectations with an applicant, including but not limited to any impact an applicant’s acceptance of the job might have on their unvested equity or deferred compensation, so long as the employer does not inquire into salary history.
PAY TRANSPARENCY REQUIREMENTS
In addition to the new restrictions on inquiring into an applicant’s compensation history, covered employers will be required under the new law to provide a salary range or scale in any job posting, advertisement, or notification. This includes postings used in the PERM recruitment process for employers sponsoring foreign nationals for green cards.
Section 669.01(i) of the Cleveland Codified Ordinances defines “salary” as “a person’s financial compensation in exchange for labor, including but not limited to wages, commissions, hourly earnings, and other monetary earnings, and also includes benefits.”
ENFORCEMENT
The Cleveland Fair Employment Wage Board (“FEWB”) is empowered under the new law to investigate complaints and seek redress. Any person may file a complaint within 180 days of an alleged violation.
The FEWB seeks to resolve disputes through education and reconciliation. The complaint will be considered resolved with no further action taken if within 90 days of the FEWB receiving the complaint, and a copy being provided to the employer, the employer has (1) corrected its deficient processes, policies, and/or application materials and (2) provided to the FEWB a credible plan to commit no further violations of the law.
If a complaint is not resolved within 90 days, the FEWB may impose a civil penalty of $1,000 for the first violation, $2,500 for the second violation, and $5,000 for each subsequent violation within a five-year period. Employers may appeal any civil penalty.
EXCEPTIONS
Ordinance No. 104-2025 does not apply to:
- Internal transfers or promotions.
- Reliance on compensation history as authorized under local, state, or federal law.
- Any voluntary and unprompted disclosures by an applicant.
- Compensation history discovered through a background check or while verifying non-compensation information, so long as the discovered information is not utilized to determine the applicant’s compensation.
- Re-hired employees for whom the employer already has the compensation history.
- Employees covered by collective bargaining agreements.
- Government employees, except for those employed by the City of Cleveland.
Employers should contact their legal counsel now to ensure hiring practices and job postings are fully compliant before the law takes effect on October 27, 2025.
Tagged In:Employee CompensationEmployment & LaborEmployment LawHuman Resources CounselingPay TransparencyRegulatory Compliance