Compliance — District of Columbia

District of Columbia pay transparency compliance.

Coverage thresholds, what has to be disclosed and filed, by when, and what happens if it isn’t — for employers with people in District of Columbia.

District of Columbia

What District of Columbia actually requires

The District has the steepest penalty escalation in the country — $1,000, then $5,000, then $20,000 for each subsequent violation — and it applies to employers with a single DC employee.

D.C. Law 25-138 — § 32-1453.01

Pay range and health benefits

Effective 5 March 2024, compliance from 30 June 2024. Applies to any employer with at least one employee in the District.

In the listing
The minimum and maximum projected salary or hourly pay in all job listings and position descriptions advertised — good faith, at the time of posting
Internal too
Covers job, promotion and transfer opportunities, so internal postings are in scope
Before interview
Disclose the existence of healthcare benefits to prospective employees before the first interview — not necessarily in the posting
Not required
Bonuses, equity and other compensation need not be listed
§ 32-1453.02 and § 32-1455

The notice, and the escalation

Two provisions that catch employers who did the posting work and stopped there.

Post a notice
Employers must post a notice of employee rights under Chapter 14A in a conspicuous place in at least one location where employees congregate
Salary history
Employers may not screen on wage history, require its disclosure as a condition of interview or consideration, or seek it from a previous employer
Penalty
$1,000 first violation, $5,000 second, $20,000 each subsequent
Enforcement
The Mayor administratively and the Attorney General by civil action — restitution, injunctive and compensatory relief, fees and costs. No private right of action
In detail

The parts that catch employers out

One employee is enough

§ 32-1451 defines “employer” as any individual, firm, association or corporation employing at least one employee in the District, excluding District and federal government entities. There is no minimum headcount — broader than California’s 15, Massachusetts’ 25, or Minnesota’s 30.

For the many national associations, foundations and advocacy organisations headquartered in the District, that means coverage is effectively universal.

The healthcare disclosure is a process requirement, not a posting requirement

§ 32-1453.01(a)(2) requires employers to disclose the existence of healthcare benefits that employees may receive before the first interview. The trigger is the interview, not the advert — health benefits do not have to appear in the posting itself.

This is the provision employers most often miss, because it lives in the recruiting workflow rather than the job description template. Building it into the interview scheduling confirmation is the simplest fix.

The employee notice

§ 32-1453.02 requires a posted notice informing employees of their rights under Chapter 14A, in a conspicuous place in at least one location where employees congregate. The statute does not prescribe the text and leaves content to be developed.

Whether DOES has issued an official model poster is not something we have been able to confirm. Several law firms circulated their own sample notices in the absence of one. If you have DC employees and no notice posted, that is worth raising with counsel rather than waiting for a model.

Why the escalation matters more than the first number

$1,000 for a first violation reads as trivial. The structure is the point: $5,000 for the second and $20,000 for each subsequent violation, with no cure period of the kind Massachusetts, Washington and New York City provide.

An employer running a systematic error — a posting template missing the range, an ATS that strips it, an agency posting on the employer’s behalf without it — is not exposed once. The DC Attorney General issued a business advisory restating these requirements on 23 July 2025, which is generally how an enforcement posture announces itself.

No recordkeeping requirement

Chapter 14A contains no recordkeeping or retention provision — a notable contrast with Maryland’s three-year, per-posting rule just across the line. Employers operating across the DC–Maryland–Virginia boundary generally end up applying Maryland’s standard everywhere, because maintaining two record regimes for one recruiting function is more expensive than the retention itself.

Getting ready

A workable sequence

We support District of Columbia 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 Washington DC executive compensation page.

Common questions

District of Columbia pay compliance

Does the DC pay transparency law apply to small employers?

Yes. The statute defines an employer as any individual, firm, association or corporation employing at least one employee in the District, excluding District and federal government entities. There is no size threshold, which makes DC broader in coverage than California, Massachusetts, Minnesota or Washington.

What are the penalties under the DC Wage Transparency Omnibus Amendment Act?

They escalate steeply: $1,000 for a first violation, $5,000 for a second, and $20,000 for each subsequent violation. Enforcement is by the Mayor administratively and by the Attorney General through civil action, which may seek restitution and injunctive or compensatory relief plus fees and costs. There is no private right of action and no statutory cure period.

Does District of Columbia pay transparency law apply to remote workers?

Generally yes, where the role could be performed in District of Columbia or reports into a District of Columbia 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.

Is this page legal advice?

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.

Get in touch

Get ahead of the filing.

Pay equity analysis and range architecture, sequenced so findings can be acted on rather than merely disclosed.

Thanks — your message is on its way. We’ll follow up shortly.
Send a message

Tell us what you’re working through and we’ll follow up directly.

Fields marked * are required. We use your details only to reply to your enquiry.