Promotion and transfer pay disclosure requirements vary by state. Washington requires covered employers to provide the wage scale or salary range for a new position to an employee offered an internal transfer or promotion upon request. Massachusetts requires covered employers to provide the pay range when an employee is offered a promotion or transfer to a new position with different job responsibilities. Connecticut also requires wage-range disclosure at specified internal employment events, including position changes and employee requests. Illinois uses a different model: an externally published specific job posting can trigger a duty to notify current employees of promotional opportunities within 14 calendar days. Hawaii, by contrast, excludes internal transfers and promotions from its job-listing disclosure requirement. Employers should therefore use a state-by-state internal mobility workflow rather than one national rule.
Jurisdiction: United States
Internal Mobility Can Trigger Pay Transparency Duties Even Without an External Job Posting
Pay transparency compliance does not stop at the careers page. Promotions, transfers, reassignments and other internal moves can create separate disclosure duties under state law. The trigger varies by jurisdiction. Some states require the employer to provide a wage scale or pay range when an employee is offered a new internal position. Others require disclosure only when the employee requests it. Illinois adds a different concept by linking externally published job opportunities to an obligation to tell current employees about promotional opportunities. Employers should therefore build internal mobility rules into HR workflows rather than assuming that salary transparency matters only during external recruitment.
Washington Requires Range Disclosure for Covered Internal Transfers and Promotions
Washington's Equal Pay and Opportunities Act requires employers with 15 or more employees to provide the wage scale or salary range of a new position to an employee who is offered an internal transfer or promotion, upon the employee's request. If the employer offers only a fixed wage amount, that fixed amount must be disclosed instead. Washington guidance treats a broad range of movements between positions as potential internal transfers, including promotions, demotions, reallocations and other job changes. Employers should therefore make the approved range readily available to HR and managers before the offer is communicated.
Massachusetts Requires Pay Range Disclosure When the Internal Offer Is Made
Massachusetts uses a more direct trigger. Beginning October 29, 2025, covered employers with 25 or more employees must provide the pay range for a particular and specific position to an employee who is offered a promotion or transfer to a new position with different job responsibilities. The law also gives employees the right to request the pay range for their current position. The pay range is the annual salary or hourly wage range the employer reasonably and in good faith expects to pay at that time. HR systems should therefore connect promotion and transfer approvals to the current approved range before the offer is delivered.
Connecticut Uses Position-Change and Request Triggers
Connecticut's wage-range disclosure framework is not primarily a general job-posting rule. Instead, the law requires employers to provide the wage range to an employee when the employee is hired, when the employee changes to a new position, and when the employee requests the range for the employee's position. Applicants also have disclosure rights under the statute. That means an internal transfer or promotion can create a disclosure duty even when no external advertisement exists. Employers should train HR staff to treat position changes as compliance events and not wait for the employee to search for compensation information independently.
Illinois Separately Regulates Promotional Opportunity Notice
Illinois combines pay transparency with a promotional-opportunity rule. An employer with 15 or more employees that externally publishes a specific covered job posting must, within 14 calendar days, make all opportunities for promotion known to current employees. The rule does not require employers to publish every vacancy externally, and an internal-only opportunity that is never externally posted does not trigger this promotional-opportunity requirement. Illinois therefore differs from states that focus on a pay-range disclosure at the moment an internal offer is made. Employers should separately track the date an external posting goes live and the date current employees are notified.
Hawaii Shows Why Internal Mobility Exceptions Must Be Tracked Separately
Hawaii's job-listing disclosure rule expressly excludes positions that are internal transfers or promotions within a current employer. That does not create a general exemption from equal-pay, discrimination or other employment law, but it does mean the specific job-listing range requirement does not apply to those internal moves. This contrast is important for multi-state employers. A transfer that requires a range disclosure in Washington or Massachusetts may fall outside Hawaii's posting rule. Compliance matrices should therefore include an internal-mobility column rather than relying only on the external job-posting requirements for each state.
Create an Internal Mobility Disclosure Checklist
A practical process starts by identifying the employee's work state, the destination role, whether job responsibilities change, whether the opportunity was advertised externally and whether the employee has requested pay information. HR should then determine the applicable disclosure trigger, confirm the current approved range or fixed rate, record when the information was provided and preserve any required notice evidence. The same workflow can flag whether benefits, other compensation or a broader posting disclosure is required. This prevents internal moves from bypassing controls that already exist for external recruiting and creates a consistent record if the decision is later reviewed.
Frequently Asked Questions
Do promotions always require a salary range disclosure?
No. The trigger varies by state. Some states require disclosure when a promotion is offered, some require it on request or at a position change, and others exclude internal promotions from the job-posting rule.
Does Washington require pay disclosure for internal transfers?
Yes. Covered employers must provide the wage scale or salary range for the new position to an employee offered an internal transfer or promotion upon request.
Does Illinois require every promotion to be posted internally?
No. Illinois generally triggers its promotional-opportunity duty when a covered employer externally publishes a specific job posting. It must then make promotional opportunities known to current employees within 14 calendar days.
Related Guides
Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.