Coverage thresholds, what has to be disclosed and filed, by when, and what happens if it isn’t — for employers with people in Minnesota.
Minnesota’s pay transparency statute has a mandate and no stated penalty. That is not a reason to relax — it is a reason to understand where the actual exposure sits.
Employers with 30 or more employees at one or more sites in Minnesota. Effective 1 January 2025. One date, no staggering.
A separate regime, and the one with real teeth in Minnesota.
Section 181.173 contains no penalty subdivision and specifies no dollar amount. This is a real statutory gap and practitioners have noted it widely.
The Department of Labor and Industry commissioner’s compliance-order authority under Minn. Stat. § 177.27 subd. 4 enumerates specific statutes and does not list § 181.173. Whether a private right of action exists is likewise unresolved — § 181.171, the Chapter 181 civil action provision, does not enumerate it either. Commentary points to possible enforcement through the Attorney General or general Chapter 181 remedies, but no specific mechanism is established by statute.
We are not going to put a Minnesota penalty figure on this page, because there isn’t one. Anyone quoting you a number for Minnesota is extrapolating.
Three places, none of them § 181.173 penalties.
Unlike Massachusetts and Washington, Minnesota provides no warning or cure window. There is nothing to cure into, because there is no stated penalty to avoid — but equally there is no statutory grace if the enforcement position changes.
Minnesota requires a general description of all benefits and other compensation, including health or retirement benefits. Massachusetts requires none. Washington requires a general description. Colorado requires a general description and prohibits vague phrasing.
For a multi-state employer this is the practical problem: a single posting template has to satisfy the strictest requirement across every state the role touches, or you need conditional templates. Most organisations pick the former and discover it means writing to Colorado’s standard everywhere.
We support Minnesota employers on the compensation side of this — pay equity analysis, range architecture, and how executive pay reads inside a filing or a published range. We are not attorneys and this page is not legal advice; the filings themselves are usually handled with employment counsel.
For advisory work in the region, see our Minneapolis executive compensation page.
The statute does not specify one. Minn. Stat. § 181.173 contains no penalty subdivision and no dollar amount, the DLI commissioner's compliance-order authority under § 177.27 subd. 4 does not enumerate it, and § 181.171 does not establish a private right of action for it. Enforcement may be possible through the Attorney General or general Chapter 181 remedies, but no specific mechanism exists in statute. Any figure quoted to you for Minnesota is an extrapolation.
Yes. Minnesota requires a general description of all benefits and other compensation, including health or retirement benefits — broader than Massachusetts, which requires no benefits disclosure at all. For multi-state employers this usually means writing postings to the strictest applicable standard rather than maintaining separate templates.
Generally yes, where the role could be performed in Minnesota or reports into a Minnesota supervisor, office or worksite. The specifics vary — some states test on where the work is performed, others on the reporting line, and several catch out-of-state employers recruiting locally-based remote staff. Check the coverage language above against your own arrangements rather than assuming a headquarters test.
No. It is a compensation practitioner's summary of published requirements, current as at July 2026, intended to help you scope the compensation work these obligations create. Pay legislation in this area has been amended frequently and several provisions carry sunset dates. Confirm current requirements with employment counsel before acting.
Pay equity analysis and range architecture, sequenced so findings can be acted on rather than merely disclosed.
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