Oregon Pay Transparency Act

Relating to disclosures of certain information concerning employment-related matters; prescribing an effective date.

United States

RET-US-OR-HB27460-2025

Effective: September 26, 2025
In Force(In Force)
ActPay Transparency in HiringPay History BansWage Discussion Rights

Oregon House Bill 2746 (2025) mandates comprehensive pay transparency requirements for employers and employment agencies, requiring disclosure of wage ranges and benefits in job postings and to applicants and employees upon request. It reinforces prohibitions on salary history inquiries and protects employees' rights to discuss wages without retaliation. The Act also outlines enforcement mechanisms through the Bureau of Labor and Industries (BOLI), including civil penalties and educational outreach, aiming to combat pay inequity and foster a more transparent and equitable labor market in Oregon.

Overview

Oregon House Bill 2746, enacted in 2025, represents a significant legislative stride towards enhancing pay equity and transparency within the state's employment landscape. The Act, titled "Relating to disclosures of certain information concerning employment-related matters; prescribing an effective date," was introduced to address persistent pay gaps, particularly those affecting women, people of color, individuals with disabilities, and LGBTQ+ workers. The legislative intent behind HB 2746 is rooted in the recognition that pay secrecy often perpetuates discriminatory hiring and compensation practices, leading to systemic disparities. By mandating greater transparency, the Act seeks to empower job seekers and current employees with the information necessary to make informed decisions and advocate for fair compensation, thereby fostering a more equitable and inclusive job market across Oregon. This proactive approach aims to dismantle historical barriers to equal pay and promote economic justice for all workers in the state.

The historical context for HB 2746 is built upon a growing national movement towards pay transparency and equal pay legislation, reflecting a broader societal demand for fairness in compensation. Many states and localities have, in recent years, adopted laws requiring salary range disclosures in job postings or prohibiting salary history inquiries. Oregon itself had prior legislation aimed at pay equity, notably the Oregon Equal Pay Act of 2017, but HB 2746 expands upon these efforts by creating a more comprehensive and proactive framework. The bill was sponsored by Representative Nelson and Senator Jama, with additional regular sponsors including Representative Chaichi and Senator Pham, indicating broad legislative support for its objectives. Its passage reflects a societal shift towards greater accountability for employers in ensuring fair compensation practices and a proactive approach to dismantling barriers that contribute to wage disparities, positioning Oregon as a leader in this critical area of employment law.

Key innovations of HB 2746 include its dual focus on proactive disclosure in job postings and the reinforcement of employee rights regarding wage discussions and protection against retaliation. The Act not only requires employers and employment agencies to include wage and benefit information in job advertisements but also mandates the maintenance of detailed employment records, which are crucial for enforcement and monitoring. Furthermore, it tasks the Commissioner of the Bureau of Labor and Industries (BOLI) with conducting extensive outreach and training to ensure compliance, alongside establishing clear enforcement mechanisms, including civil penalties. This comprehensive approach, combining preventative measures with robust enforcement and educational initiatives, underscores the Act's ambition to create lasting change in Oregon's employment practices. The law's impact is expected to be far-reaching, influencing hiring strategies, compensation structures, and overall workplace culture by promoting a standard of openness and fairness in pay-related matters, ultimately aiming to reduce pay gaps across various demographics.

Definitions

Central to the understanding and application of Oregon House Bill 2746 are several key definitions that delineate the scope and requirements of the Act. While the full text of the Act would provide precise legal definitions, based on the summary and common legal parlance in pay equity legislation, several terms are critical. "Wage" or "wage range" refers to the compensation offered for a position, typically expressed as a minimum and maximum hourly rate or salary. This definition is crucial for the pay transparency requirements, as employers must disclose this range in job postings. The intent is to provide applicants with a clear understanding of the potential earnings for a role, preventing situations where individuals might unknowingly apply for positions that do not meet their financial expectations or where pay is arbitrarily determined during negotiations. The Act aims to standardize this disclosure, ensuring consistency and clarity across all advertised positions, thereby fostering a more equitable starting point for all applicants.

"Employment-related matters" encompasses a broad array of issues pertinent to the employer-employee relationship, including but not limited to hiring, promotion, transfer, compensation, benefits, and working conditions. This broad definition ensures that the disclosure requirements and anti-retaliation provisions of HB 2746 apply comprehensively across various stages of employment. The Act specifically targets disclosures concerning "employment-related matters," indicating that the transparency mandates extend beyond just initial job offers to internal opportunities as well. This holistic approach is designed to prevent pay inequities from arising or persisting at any point in an employee's career trajectory within an organization, from initial application through promotions and transfers. The comprehensive nature of this definition ensures that the spirit of pay equity is maintained throughout an individual's tenure.

An "employer" under this Act typically refers to any person or entity that employs one or more individuals in Oregon. This definition is generally broad to ensure wide applicability of the law, covering private businesses, non-profit organizations, and public sector entities. "Employment agency" refers to any person or entity that procures employees for an employer or procures opportunities for employment for individuals. The inclusion of employment agencies is significant because it extends the pay transparency and salary history inquiry prohibitions to third-party recruiters, preventing them from circumventing the law's intent. This ensures that the entire hiring ecosystem, from direct employers to agencies facilitating placements, adheres to the new transparency standards. The Act also implicitly defines "benefits" as part of the compensation package that must be disclosed, which would typically include health insurance, retirement plans, paid time off, and other non-wage forms of remuneration, providing a complete picture of the total compensation for a role and allowing for comprehensive comparisons.

Covered Employers

Oregon House Bill 2746 applies broadly to most employers and employment agencies operating within the state of Oregon, demonstrating a commitment to universal pay equity standards. The legislative summaries indicate that the requirements extend to "employers and employment agencies," without specifying explicit size thresholds or industry-specific exemptions in the initial digest. This suggests a wide-ranging applicability, encompassing small businesses, large corporations, non-profit organizations, and public sector entities alike. The intent behind such broad coverage is to ensure that the principles of pay transparency and equity are upheld across the entire Oregon labor market, preventing loopholes that could allow certain employers to avoid compliance. This inclusive approach ensures that the benefits of pay transparency are extended to the vast majority of Oregon's workforce, regardless of where they are employed.

While the initial summaries do not detail specific exemptions, it is common for employment laws to have limited exceptions for certain types of employers or employment relationships, such as independent contractors, temporary workers, or very specific governmental functions that operate under distinct regulatory frameworks. However, the primary focus of HB 2746 is clearly on standard employer-employee relationships and the crucial role of employment agencies in facilitating these. The Act's provisions are designed to impact the hiring and compensation practices for any position that could be performed, in whole or in part, within Oregon, including remote or hybrid roles where the employee resides in Oregon. This broad jurisdictional reach ensures that employers cannot circumvent the law by hiring Oregon residents for remote positions while basing their operations outside the state, thereby protecting a wider segment of the Oregon workforce and preventing jurisdictional arbitrage.

The Act's effective date, 91 days after sine die of the 2025 legislative session, with some provisions taking effect on September 26, 2025, and others on January 1, 2026, indicates a phased-in approach to compliance. This timeline provides employers and employment agencies with a reasonable period to adjust their hiring practices, update job posting templates, and train their human resources and recruitment staff on the new requirements. The Bureau of Labor and Industries (BOLI) is explicitly directed to conduct proactive outreach and ongoing training to educate these entities about the new requirements, further supporting a smooth transition to full compliance. This emphasis on education and a staggered implementation suggests a pragmatic approach to integrating these significant changes into the state's employment practices, aiming for broad and effective adoption rather than immediate, punitive enforcement for initial non-compliance.

Employee Rights

Oregon House Bill 2746 significantly bolsters employee rights concerning pay transparency and protection against discriminatory practices, empowering individuals with critical information and safeguards. A cornerstone of these new rights is the entitlement to receive specific wage and benefit information. Employees and job applicants now have the right to be informed of the wage range, a general description of benefits, and any other compensation associated with a job, promotion, or transfer opportunity. This information must be proactively included in all job postings, both external and internal. Furthermore, job applicants have the right to request and receive this comprehensive compensation information before any salary discussions or offers are made, ensuring they are fully informed during negotiations. Current employees are also entitled to this information at the time of hire, transfer, or promotion, and can request it once per calendar year, allowing them to monitor their compensation relative to internal standards. These provisions empower individuals to negotiate more effectively and to identify potential pay disparities, fostering a more informed and equitable negotiation process.

Another critical right reinforced by HB 2746 is the protection against inquiries into salary history. Oregon law already prohibited employers from asking about past wages, and this Act strengthens that prohibition, extending it explicitly to employment agencies. This ensures that an individual's past earnings, which may have been influenced by discriminatory practices, do not perpetuate pay inequity in future roles. By focusing on the inherent value of the position and the applicant's qualifications rather than their previous salary, the law aims to break cycles of underpayment and promote fair compensation based on merit and market rates. This right is fundamental to achieving true pay equity, as it prevents employers from anchoring new salary offers to potentially biased historical data, thereby promoting a fresh start for all applicants regardless of their prior compensation history.

Crucially, the Act makes it an unlawful employment practice for an employer or employment agency to retaliate or discriminate against an employee for invoking or exercising any of their rights under this law. This anti-retaliation provision is vital for ensuring that employees feel secure in exercising their rights, such as requesting pay information, discussing wages with colleagues, or filing a complaint with BOLI, without fear of adverse employment actions like demotion, termination, or reduced opportunities. The ability to freely discuss wages and compensation with colleagues is also implicitly protected, as such discussions are often necessary for employees to identify potential pay disparities and exercise their rights effectively. The Act's emphasis on protecting these rights underscores its commitment to creating a workplace culture where transparency is encouraged and employees are empowered to advocate for fair treatment without fear of reprisal, thereby fostering a more just and open work environment.

Pay Transparency Requirements

Oregon House Bill 2746 establishes robust pay transparency requirements, primarily centered on the proactive disclosure of compensation information in job postings. The Act mandates that employers and employment agencies must include the wage or wage range, a general description of employment benefits, and any other compensation in all advertisements for job, promotion, and transfer opportunities. This requirement applies to both external job advertisements, visible to the general public, and internal postings for promotions or transfers, ensuring a consistent standard of transparency across all hiring and advancement opportunities within an organization. The goal is to provide prospective and current employees with a clear understanding of the potential earnings and overall compensation package before they invest time and effort in the application or interview process. This proactive disclosure is a significant step towards eliminating pay secrecy, which has historically contributed to wage disparities and limited informed decision-making by job seekers.

Beyond job postings, the Act extends pay transparency obligations to direct interactions with applicants and employees, ensuring information is available at critical junctures. Employers are required to provide the same comprehensive compensation information (wage range, benefits, and other compensation) to job applicants upon request, and specifically before any compensation discussion or offer takes place. This ensures that applicants are fully informed at critical stages of the hiring process, allowing them to negotiate from a position of knowledge. For current employees, the law mandates that this information be provided at the time of hire, transfer, or promotion, ensuring internal equity is maintained and understood. Furthermore, employees have the right to request this information once per calendar year, allowing them to stay informed about the compensation structure for their roles and comparable positions within the organization, fostering ongoing transparency. These provisions collectively aim to create an environment where compensation is transparent and understandable, reducing the likelihood of arbitrary or discriminatory pay practices.

The specific deadlines for compliance with these pay transparency requirements are tied to the Act's effective date. While the overall Act takes effect 91 days after sine die of the 2025 legislative session (approximately late September/early October 2025), some specific provisions, such as those related to age disclosure prohibitions, became effective as of September 26, 2025. Employers should consult the final enacted text for precise effective dates for each component of the pay transparency requirements, as a phased implementation is often designed to allow businesses ample time to adapt. The Bureau of Labor and Industries (BOLI) is tasked with conducting proactive outreach and ongoing training to educate employers and employment agencies about these new requirements. This educational component is crucial for ensuring widespread understanding and compliance, particularly for smaller businesses that may have fewer resources to track legislative changes. The comprehensive nature of these requirements positions Oregon at the forefront of pay transparency efforts nationally, setting a high standard for fair hiring and compensation practices.

Reporting & Audit Obligations

Oregon House Bill 2746 introduces new obligations for employers related to record-keeping, which indirectly supports future reporting and audit capabilities, though it does not explicitly mandate regular pay gap reporting or external audits in the same way some other jurisdictions do. The Act specifically "Requires employers to maintain certain employment records for each employee." While the exact nature and duration of these record-keeping requirements would be detailed in the full text of the Act or subsequent regulations, this provision is foundational for monitoring pay equity. These records would typically include details on wages paid, benefits provided, job titles, dates of hire and promotion, performance evaluations, and other compensation-related data. Such comprehensive record-keeping is essential for the Bureau of Labor and Industries (BOLI) to effectively investigate complaints, conduct compliance reviews, and assess civil penalties when violations occur, ensuring accountability and data-driven enforcement.

Although the Act's initial summaries do not detail specific, recurring pay gap reporting obligations for employers (e.g., annual reports on gender or race pay gaps), the emphasis on maintaining employment records suggests that BOLI will have the necessary data to conduct its own analyses or to request information during investigations. This data could potentially be used in the future to inform policy decisions regarding the necessity of mandatory pay gap reporting, should the state determine it is needed to further address pay disparities. The directive for BOLI to conduct "proactive outreach and ongoing training to educate employers and employment agencies about the requirements" also implies a focus on preventative compliance rather than solely reactive enforcement. This educational approach could include guidance on best practices for record-keeping that would facilitate internal pay equity audits by employers, even if not explicitly mandated by the state. Such internal audits, while voluntary, would help employers identify and rectify potential disparities before they lead to formal complaints or BOLI investigations, promoting self-correction.

The Act empowers the Commissioner of BOLI to assess civil penalties for violations, which inherently implies a process of investigation and potentially an audit of an employer's practices and records. While the Act permits BOLI to issue a letter of explanation or education for a first violation instead of a civil penalty, this discretion would likely be exercised after an initial review or inquiry into the alleged violation, which would necessitate access to employer records. This suggests that BOLI will have the authority to request and review relevant employment records as part of its enforcement and educational functions, ensuring that compliance can be verified. The long-term implications of these record-keeping requirements are significant, as they lay the groundwork for more robust monitoring and evaluation of pay equity across Oregon, even if formal, employer-initiated pay gap reporting is not an immediate feature of the legislation. This foundational data collection is a critical step towards comprehensive pay equity oversight.

Governance & Enforcement Bodies

The primary governance and enforcement body for Oregon House Bill 2746 is the **Bureau of Labor and Industries (BOLI)**, led by its Commissioner. BOLI is a state agency with a long-standing history of responsibility for enforcing civil rights and wage and hour laws in Oregon, making it the natural and most experienced authority to oversee the implementation and compliance of this new pay transparency legislation. The Act explicitly directs the Commissioner of BOLI to undertake several key responsibilities, including conducting "proactive outreach and ongoing training to educate employers and employment agencies about the requirements." This educational mandate highlights BOLI's dual role not just as an enforcer, but also as a vital resource for employers seeking to understand and adhere to the new legal framework. BOLI's existing infrastructure for handling wage and hour complaints and civil rights investigations will be leveraged and adapted to address violations of HB 2746, ensuring efficient and consistent enforcement.

BOLI's enforcement powers under HB 2746 are significant and designed to ensure compliance with the Act's provisions. The Act states that a violation of its provisions constitutes an "unlawful practice" under Oregon law, which triggers BOLI's authority to intervene. The Commissioner is empowered to "assess civil penalties for a violation," which can include monetary fines. The process for filing a complaint with BOLI typically involves an individual submitting a formal complaint form through BOLI's website or physical offices, after which BOLI's civil rights division would initiate an investigation. This investigation may include gathering evidence, interviewing parties, reviewing employment records (as mandated by the Act), and potentially attempting mediation. BOLI also has the discretion to issue a "letter of explanation or education" instead of a civil penalty for a first violation, indicating a balanced approach that prioritizes education and corrective action for initial infractions, particularly for employers who demonstrate a willingness to comply.

The interaction between BOLI and other state agencies or judicial bodies would primarily occur during appeals or more complex legal challenges. If an employer disputes BOLI's findings or assessed penalties, they would typically have avenues for administrative appeal within BOLI, followed by potential judicial review in Oregon's state courts, ensuring due process. BOLI also collaborates with other state agencies, such as the Department of Justice, on legal matters and enforcement actions when necessary. The Act also specifies that the remainder of sums collected as penalties, after application toward reimbursement of costs, are to be paid into the State Treasury and credited to the General Fund. This financial mechanism underscores the state's commitment to funding the enforcement and administrative costs associated with the Act, ensuring BOLI has the resources to effectively carry out its mandate. BOLI's role as the central authority ensures a consistent and specialized approach to enforcing pay equity and transparency across Oregon, fostering a fair and compliant labor market.

Monitoring & Evaluation

The monitoring and evaluation of Oregon House Bill 2746's effectiveness will primarily fall under the purview of the Bureau of Labor and Industries (BOLI), which is tasked with ensuring ongoing compliance and assessing the impact of the law. While the Act does not explicitly detail a formal, periodic evaluation framework with specific reporting metrics for the public, BOLI's ongoing responsibilities for enforcement, outreach, and training inherently involve continuous monitoring of compliance and the practical impact of the law on employers and employees. Inspection procedures would likely be primarily complaint-driven initially, where BOLI investigates alleged violations of the pay transparency and anti-retaliation provisions. Upon receiving a complaint, BOLI's investigators would gather evidence, which could include reviewing job postings, internal compensation policies, employment records (as mandated by the Act), and interviewing relevant parties. This data collection is crucial for understanding patterns of non-compliance and areas where further guidance may be needed.

The process for investigating complaints will follow BOLI's established procedures for civil rights and wage and hour complaints, ensuring consistency and fairness. This typically involves an intake process where the complaint is reviewed for jurisdiction and sufficiency, followed by potential mediation attempts to resolve disputes amicably. If mediation is unsuccessful, a formal investigation commences, leading to a determination of whether a violation occurred. The Act's provision allowing BOLI to issue a letter of explanation or education for a first violation suggests a tiered approach to enforcement, where initial non-compliance might be met with educational guidance rather than immediate penalties. This approach aims to foster voluntary compliance through understanding, rather than solely through punitive measures, especially for employers who are genuinely attempting to adapt to the new regulations. BOLI's proactive outreach and ongoing training initiatives also serve as a form of monitoring, as they allow the agency to gauge employer understanding and identify common areas of confusion or non-compliance, which can then inform future educational efforts and policy adjustments.

While the Act does not specify an audit frequency for employers, BOLI's authority to assess civil penalties implies the ability to conduct compliance reviews or audits as deemed necessary, particularly in response to patterns of complaints, in industries identified as high-risk for pay disparities, or as part of broader enforcement initiatives. The evaluation criteria for the Act's success would likely include metrics such as the number of complaints received and resolved, the types and frequency of violations identified, the impact on reported pay gaps (if data becomes available through other means or future legislation), and the overall level of employer compliance with the disclosure requirements. The effectiveness of BOLI's outreach and training programs, measured by participation rates and feedback, would also be a key indicator of the Act's successful implementation. Over time, legislative bodies may also review the Act's impact and consider amendments based on BOLI's experience and broader economic and social outcomes related to pay equity in Oregon, ensuring the law remains relevant and effective in achieving its goals.

Enforcement & Penalties

Oregon House Bill 2746 establishes clear enforcement mechanisms and outlines the penalties for non-compliance, primarily through the Bureau of Labor and Industries (BOLI). The Act designates a violation of its provisions as an "unlawful practice" under Oregon law, which triggers BOLI's authority to intervene and take corrective action. The Commissioner of BOLI is empowered to "assess civil penalties for a violation." While the specific fine amounts or penalty ranges are not detailed in the initial legislative summaries, such details would typically be outlined in the full text of the Act or in subsequent administrative rules promulgated by BOLI. These civil penalties are designed to deter non-compliance and ensure that employers and employment agencies adhere to the pay transparency, salary history inquiry prohibitions, and anti-retaliation requirements, providing a tangible consequence for failing to meet legal obligations.

The Act introduces a nuanced approach to penalties, allowing for discretion in enforcement to encourage voluntary compliance and education. Specifically, it "Permits the commissioner to issue a letter of explanation or education to an employer or employment agency instead of a civil penalty for a first violation." This provision indicates a preference for education and corrective action for initial, less severe infractions, rather than immediate punitive measures. This approach aims to foster a culture of compliance through understanding and guidance, particularly for employers who may inadvertently violate the new requirements due to unfamiliarity. However, repeated violations, intentional non-compliance, or more egregious breaches of the law would likely result in the assessment of civil penalties, with the potential for escalation depending on the severity, frequency, and impact of the non-compliance on employees. The goal is to ensure that while education is prioritized, there are meaningful consequences for persistent or deliberate disregard of the law.

In addition to civil penalties, the Act makes it an "unlawful employment practice for an employer or an employment agency to retaliate or discriminate against an employee for invoking or exercising certain rights." This anti-retaliation provision carries significant weight, as retaliation against an employee for exercising their rights under the Act (e.g., requesting pay information, discussing wages, or filing a complaint) could lead to separate and potentially more severe penalties. Remedies for affected employees in retaliation cases can include back pay, front pay, reinstatement, damages for emotional distress, and attorney's fees. While criminal liability is not typically associated with these types of civil employment law violations, the financial and reputational costs of non-compliance, coupled with potential legal actions by aggrieved employees (including private rights of action in some cases under Oregon law), provide strong incentives for employers to adhere to the Act. Employers have the right to appeal BOLI's decisions and assessed penalties through established administrative and judicial review processes, ensuring due process in enforcement actions and allowing for legal challenges to BOLI's determinations.

Relationship to Other Laws

Oregon House Bill 2746 operates within and significantly complements a broader framework of existing state and federal employment laws, particularly those related to pay equity, anti-discrimination, and wage and hour regulations. The Act explicitly amends **ORS 659A.357 and 659A.360**, which are sections of Oregon Revised Statutes pertaining to unlawful employment practices and equal pay. This indicates that HB 2746 is not a standalone piece of legislation but rather an enhancement and expansion of existing legal protections. By amending these specific statutes, the Act integrates its new pay transparency and anti-retaliation provisions directly into Oregon's established equal pay legal framework, ensuring consistency and reinforcing the state's commitment to combating wage discrimination. This legislative approach ensures that the new requirements are seamlessly integrated into the existing legal landscape, strengthening the overall protections for workers.

The Act's prohibition on inquiring about salary history and its extension to employment agencies builds upon and strengthens Oregon's existing **Equal Pay Act**, which was significantly updated in 2017. The Oregon Equal Pay Act, like its federal counterpart (the Equal Pay Act of 1963), prohibits employers from paying employees less than employees of a different protected class for work of comparable character, unless justified by specific bona fide factors. By preventing employers from using past salary as a basis for new offers, HB 2746 helps to break the cycle of discriminatory pay practices that may have influenced previous wages, thereby directly supporting the core objective of the Equal Pay Act to ensure pay is based on merit and job value, not historical bias. Furthermore, the anti-retaliation provisions of HB 2746 align with and reinforce similar protections found in other anti-discrimination laws, such as Title VII of the Civil Rights Act of 1964 (federal) and the Oregon Fair Employment Practices Act, which prohibit retaliation against individuals for exercising their protected rights, creating a robust shield for employees.

In cases of potential conflict between HB 2746 and other laws, the principle of precedence generally dictates that the law providing greater protection to employees will prevail. Given that HB 2746 introduces more stringent pay transparency and disclosure requirements than many existing federal laws, it is likely to set a higher standard for employers in Oregon. For example, while federal law does not generally mandate salary disclosures in job postings, Oregon's law now does. The Bureau of Labor and Industries (BOLI), as the primary enforcement agency, will be responsible for interpreting and applying HB 2746 in conjunction with other relevant state and federal laws, ensuring a cohesive and comprehensive approach to employment law compliance. This includes providing guidance to employers on how to navigate overlapping requirements. The Act's focus on proactive disclosure and employee empowerment complements the reactive enforcement mechanisms of many anti-discrimination statutes, working together to create a more transparent and equitable labor market that addresses pay disparities from multiple angles.

International Context

Oregon's House Bill 2746 aligns with a growing international trend towards greater pay transparency and concerted efforts to close persistent gender and other identity-based pay gaps. Globally, there is increasing recognition that pay secrecy contributes significantly to these disparities, hindering individuals' ability to negotiate fair wages and perpetuating systemic inequalities. Legislative measures are being adopted in various countries and regions to address this. The principles underpinning HB 2746 resonate strongly with the **International Labour Organization (ILO) Convention No. 100 concerning Equal Remuneration for Men and Women Workers for Work of Equal Value (1951)** and **Convention No. 111 concerning Discrimination in Respect of Employment and Occupation (1958)**. While the United States has not ratified these specific conventions, their core tenets of equal pay for work of equal value and non-discrimination in employment are reflected in U.S. federal and state laws, including Oregon's new Act. HB 2746's emphasis on transparency and the prohibition of salary history inquiries directly supports the goal of eliminating discriminatory pay practices, a central aim of these foundational ILO conventions, demonstrating a shared global commitment to fair labor practices.

Furthermore, the Act's provisions mirror significant developments seen in other advanced economies, particularly within the European Union. The **EU Pay Transparency Directive**, adopted in 2023, mandates similar requirements for member states, including obligations for employers to provide information on pay ranges in job advertisements, the right for workers to request pay information, and detailed pay gap reporting for larger companies. Countries like the United Kingdom, Canada, and Australia have also implemented various forms of pay transparency or pay gap reporting legislation. While the EU Directive is broader in scope, encompassing more extensive pay gap reporting and audit obligations, Oregon's HB 2746 shares the fundamental objective of increasing transparency to combat pay discrimination and empower workers. This global movement reflects a consensus that proactive measures, beyond traditional anti-discrimination laws, are necessary to achieve true pay equity. Oregon's legislation positions the state as a leader in the U.S. in adopting comprehensive pay transparency measures that are increasingly becoming a global standard for fair employment practices, contributing to a worldwide shift towards more equitable workplaces and economic justice.

Implementation Timeline

DateMilestoneStatus
2025-03-03Bill (HB 2746) IntroducedCompleted
2025-04-03A-Engrossed House Bill 2746 Ordered by HouseCompleted
2025-06-27Oregon Legislative Session Concludes (Sine Die)Completed
2025-09-26Effective Date for some provisions (e.g., age disclosure prohibitions)In Force
2025-09-26General Effective Date for the Act (91 days after Sine Die)In Force
2026-01-01Effective Date for certain other provisions (e.g., paycheck disclosures)In Force
OngoingBOLI Proactive Outreach and Training for EmployersIn Progress

Compliance Checklist

RequirementAction RequiredDeadline
**Job Posting Pay Transparency**Include wage or wage range, general description of benefits, and other compensation in all job postings (external and internal).Effective 2025-09-26
**Applicant Pay Information Disclosure**Provide wage range, benefits, and other compensation to job applicants upon request, before any compensation discussion or offer.Effective 2025-09-26
**Employee Pay Information Disclosure**Provide wage range, benefits, and other compensation to employees at time of hire, transfer, or promotion.Effective 2025-09-26
**Annual Employee Pay Information Request**Provide wage range, benefits, and other compensation to current employees upon request (once per calendar year).Effective 2025-09-26
**Prohibition on Salary History Inquiries**Ensure no inquiries about salary history are made to applicants by employers or employment agencies.Ongoing (reinforced by HB 2746)
**Anti-Retaliation Policy Review**Review and update anti-retaliation policies to explicitly protect employees exercising rights under HB 2746.Effective 2025-09-26
**Employment Record Maintenance**Maintain comprehensive employment records for each employee, including compensation and benefit details.Ongoing (effective 2025-09-26)
**Training for Hiring Managers/HR**Conduct training for all personnel involved in hiring, promotions, and compensation decisions on new requirements.Ongoing (as soon as possible after effective date)
**Review of Compensation Practices**Conduct internal review of compensation practices to identify and address potential disparities proactively.Ongoing
**Engage with BOLI Outreach**Actively participate in or utilize resources from BOLI's proactive outreach and training programs.Ongoing

Sources and References

SourceType
Oregon Legislative Information System - HB 2746 (2025 Regular Session) Overviewofficial
Oregon Legislative Information System - A-Engrossed House Bill 2746 Textofficial
Oregon Bureau of Labor and Industries (BOLI)official

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