On October 29, 2025, Massachusetts’ Pay Transparency Law went into full effect.  Employers with 25 or more employees must disclose pay ranges for every position in 1) their job postings; 2) upon employee request; 3) and any time that an employee transfers positions within the company.

 

For NECA contractors, the transition will be smoother than most due to the existing wage transparency in collectively bargained agreements—but the law still requires formal compliance steps, documentation, and internal education.  By proactively establishing pay ranges for non-union roles and referencing CBAs for union positions, contractors can meet statutory obligations while promoting fairness and professionalism across the electrical construction industry.

 

A. Key Requirements and Terms:

  • Covered Employers: employers with 25 or more employees who primarily work in Massachusetts.  If you employ fewer than 25 employes, compliance is optional but recommended.
  • Pay Range: annual salary or hourly wage range that the employer reasonably and in good faith expects to pay for a position at the time of posting.  Employers are not required to post the actual salary for a particular position.
  • Disclosures: pay ranges must be disclosed in all job postings (internal, external, through staffing agencies); upon employee request; and any time that an employee transfers positions within the company.  Employees are only entitled to the pay range for their own position or the position to which they are being transferred.
  • Retaliation Prohibited: employers may not retaliate against applicants or employees who request pay range information or raise related concerns.
  • Liability: Employers who fail to comply with the law are subject to civil penalties. Employees may have a private right of action where an employer retaliates against employees for exercising their rights under the law.

 

B. Impact on NECA Contractors

 

Unionized Workforce (CBA Employees)

 

Most NECA contractors in Massachusetts employ union labor under collective bargaining agreements (CBAs) with the International Brotherhood of Electrical Workers (IBEW). These CBAs establish clear wage classifications for apprentices, journeymen, foremen, construction wiremen and other roles. Therefore, implications for CBA employees include:

 

  • Wage Scale Disclosure: contractors may use the wage schedule set forth in the applicable CBA as the “pay range.”  See template in Section D.
  • Consistency with Agreements: The CBA satisfies much of the “good faith” requirement, since rates are collectively negotiated. Contractors should, however, confirm that postings clearly link to the CBA wage schedule in effect.  Contractors should also review active job postings that were published before October 29, 2025 and update those postings to include the applicable pay range.
  • Employee Requests: If a current employee requests their pay range, the employer may respond by referencing the applicable CBA wage classification.
  • Multi-jurisdictional Projects: For employees dispatched across state lines, coverage depends on where their primary place of work is located—typically where the majority of their hours are performed.  Connecticut, Maine, New York, Rhode Island, and Vermont have their own pay transparency laws, and contractors are encouraged to review those laws to ensure compliance for employees on multi-jurisdictional projects in these states.

 

Although wages for these employees are collectively bargained, contractors still have an independent obligation to disclose the applicable range in job postings and to provide this information to current employees upon request.

 

Non-Union Office, Administrative, and Management Staff

 

For office employees who are typically non-union, the law also applies in full. Implications for non-union rules include:

  • Job Postings: all postings (external ads, internal announcements, and those published by staffing agencies) for Massachusetts-based or MA-remote positions must include the applicable pay range.
  • Pay Range: pay range must reflect the range that employers reasonably expect to pay at the time of posting based on internal compensation data and prior pay scales.  Contractors should audit their pay ranges for particular positions to identify accurate ranges.
  • Remote/Hybrid Workers: remote employees who report to a Massachusetts office, perform work for Massachusetts projects, or whose primary work location is MA are covered, even if they live elsewhere.
  • Pay Equity Implications: contractors should review office compensation structures to identify disparities and document how ranges are determined to demonstrate good faith.

 

Recommended Next Steps

1. Determine Applicability of Law to Your Company

    • Identify the number of employees who primarily work in Massachusetts
    • Include full-time, part-time, seasonal, and temporary employees
    • If 25 or more employees, job posting disclosure rules apply
    • If 100 or more employees, contractors must comply with the law’s wage reporting requirements (separate obligation from the pay range disclosure)

2. Develop Pay Ranges for Each Position

    • Audit positions to capture all roles that require pay ranges
    • For union roles, use the existing CBA wage scales.
    • For non-union roles, establish ranges based on current compensation ranges for each particular position
    • Document the rationale for each range to show “good faith.”

3. Update Job Posting Templates and Audit Job Descriptions

    • Ensure all external and internal postings list the applicable pay range (hourly or annual)
    • Coordinate with HR, recruiters, and project managers to standardize templates
    • Audit job descriptions to review essential functions of positions and calculate the pay ranges for particular positions

4. Employee Communication

    • Notify employees about their rights under this law
    • Train supervisors and HR staff on responding to employee requests for pay ranges
    • Communicate internally that the law prohibits retaliation for such requests

5. Conduct Pay Equity Review

    • Although not required, NECA recommends a pay equity self-audit to identify any disparities between comparable roles
    • Document findings and any corrective actions to strengthen your legal defense and demonstrate good faith

6. Multi-State Considerations

    • Contractors operating in multiple states should isolate Massachusetts postings and employees, as the law applies based on the employee’s primary work location
    • Align internal systems to ensure Massachusetts-specific compliance without over-disclosing in other jurisdictions
    • Consider laws in Connecticut, Maine, New York, Rhode Island, and Vermont concerning pay transparency and conduct comprehensive audit for positions working these states

7. Recordkeeping and Policy Development

    • Retain documentation of job postings, pay ranges, and responses to employee requests for at least three years, in case of audit or complaint
    • Employee requests and responses should be kept in employee personnel files
    • Retain documentation for any training provided to HR and project managers concerning their obligations under the law and include acknowledgment of completion in personnel files
    • Draft policy to be included in employee handbook regarding pay transparency procedures

D. Sample Posting Templates

Job Posting Template (Union Role)

Journeyman Electrician — Boston, MA
Position covered under the IBEW Local 103 Collective Bargaining Agreement.
Pay Range: $55.00 – $60.00 per hour (per current CBA wage schedule).
Benefits and pension provided per the NECA–IBEW agreement.
Equal Opportunity Employer.

 

Job Posting Template (Non-Union Office Role)

 

Project Manager — Quincy, MA (Hybrid)
Pay Range: $XX000 – $XX,000 annual base salary, depending on experience and qualifications.
Benefits include medical, retirement, and paid time off.
Equal Opportunity Employer.

 

E. Employee Communication Template

Subject: Pay Range Information Under Massachusetts Law

 

Effective October 29, 2025, Massachusetts law entitles employees to request the pay range for their current position or any position to which you are promoted or transferred.

 

You may obtain this information by contacting [HR Contact Name or Title]. Requests will be handled confidentially and without retaliation, as required by law.

 

Thank you for your continued commitment to safety, quality, and professionalism.

F. Resources and Support 

For additional assistance, contact the Greater Boston Chapter for sample policies, training materials, or coordination.