This month’s highlights:
Connecticut is flirting with “post it in the job ad” transparency like it’s still Valentine’s Day and we’re done with mixed signals, while Illinois is calling out job postings for “seeing someone else” (aka variable pay) without defining the relationship. In the EU, Denmark is serving “cozy hygge, but make it compliant,” while Italy has officially emerged from its Brussels-era situationship and is drafting its decree.
Connecticut
Connecticut’s existing framework has been more disclosure-upon-request / at key moments (offer, hire, role change, first request), rather than a blanket “salary range in every posting” rule.
The CT Department of Labor’s FAQ is still the best plain-English refresher on what’s required today.
If passed, HB 5387 would push Connecticut closer to the “post the range” camp by requiring more proactive disclosures in public and internal job advertisements. As introduced, the bill is framed to:
- Require employers to disclose wages or a wage range and a general description of benefits in public or internal job postings
- Require an annual disclosure to employees of the current wage/wage range and benefits for their position
- Reinforce anti-retaliation protections tied to wage discussion/disclosure rights
Timing: HB 5387 is described as effective October 1, 2026 in bill-tracking summaries and bill text snippets. (As always: introduced language can change fast.)
Illinois
Illinois already requires employers to post ranges in job postings. But HB 4858 is targeting a very specific pain point: job postings that give a base range but treat variable pay like a vibes-based bonus.
If passed, HB 4858, would amend the Illinois Equal Pay Act so that employers with 15+ employees must include two separate pay ranges in job postings:
- A base pay salary range (wages/salary); and
- A variable pay range (bonuses, commissions, stock, incentives, etc.)
In other words, “OTE” can’t be a mysterious all-in number that means something different depending on who’s reading it.
Europe Updates: Denmark and Italy are moving ahead
The EU Pay Transparency Directive is the gravitational force behind a lot of what’s happening right now. As a reminder, Member States must transpose it into national law by June 7, 2026.
Two themes to keep front and center because they are showing up everywhere:
- Recruiting Transparency: Candidates get the pay range (or starting pay) and employers can’t ask about salary history.
- The 5% moment: If there’s an unjustified pay gap or above a threshold (often discussed at 5%), it can trigger deeper corrective requirements, including joint pay assessments in certain circumstances.
Denmark: “hygge, but make it compliant”
Denmark just published a draft bill to amend the Equal Pay Act (ligelønsloven) to implement the EU Pay Transparency Directive. It’s a classic Scandinavian move: calm tone, serious substance, and a lot of “please document your rationale.”
Where it stands: The Danish Ministry of Employment published the proposal on February 26, 2026, set a hearing deadline of March 27, 2026, and penciled in an effective date of January 1, 2027 — because apparently Denmark, like the Netherlands, has decided that pay transparency should arrive fashionably late.
What the draft would require at a high level:
- Pay structures: Employers must use pay structures based on objective, gender-neutral criteria (and structured so “work of equal value” comparisons are possible).
- Recruiting transparency: Candidates must receive starting pay or a pay range (and relevant collective agreement terms), and employers cannot ask about salary history.
- Access to pay-setting criteria: Employers must make it easy for employees to access the objective, gender-neutral criteria used to set pay, pay levels, and pay progression.
- Employee information rights: Employees can request their own pay level and gender-based average pay for the group doing the same work / work of equal value; employers generally must respond in writing within 2 months (and notify employees annually about this right).
- Pay reporting (larger employers): Employers with 100+ employees must produce a gender pay gap statement by employee categories, including a breakdown between base pay and variable/supplementary elements.
- “5% gap” trigger: If reporting shows an unjustified ≥5% pay gap in a category (and it isn’t remedied within the specified window), the employer must complete a joint pay assessment with employee representatives.
Italy: from “la dolce vita” to “let’s draft the decree”
Italy has taken a meaningful step: on February 5, 2026, Italy’s Council of Ministers approved a draft Legislative Decree to implement the Directive, and it’s now moving through review/consultation before final adoption.
What’s notable is that Italy is progressing from concept to implementation. Elements aligned with the EU Pay Transparency Directive, particularly reporting and remediation mechanisms, are taking shape, and the work is advancing toward the June 7, 2026, transposition deadline.
February takeaways
Whether it’s Connecticut nudging toward posting requirements, Illinois demanding clearer total-comp storytelling, or EU Member States turning the Directive into local law, the common thread is simple:
Pay transparency isn’t “publish everyone’s salary.”
It’s documenting your why: ranges, criteria, progression, comparability, and the data you can stand behind when daylight hits.
Need help with pay transparency compliance? Payscale has the solution
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