Every job posting in NYC is legally required to list a real salary range, but “real” turns out to be doing a lot of work in that sentence — postings with ranges spanning $50,000 or more aren’t uncommon, and enforcement has been inconsistent enough that plenty of employers still get it wrong. Here’s how the law actually works and where it still falls short in practice.
The law covers a specific set of employers, not every job posting citywide
NYC’s salary transparency law requires employers with four or more employees to include a good-faith minimum and maximum salary in job postings for positions that could be performed, at least in part, in New York City — a scope that includes remote postings from out-of-state companies if the role could plausibly be done from NYC, not just postings for physically NYC-based offices. Employers assuming the law only applies to their local storefront or office, while treating remote postings as exempt, are applying the rule more narrowly than it actually covers.
“Good faith range” is the actual legal standard, and it has real teeth
The law specifically requires a “good faith” range reflecting what the employer genuinely expects to pay, not a deliberately padded range designed to technically comply while providing little real information — a posting listing $40,000 to $250,000 for the same role is the kind of range regulators and worker advocates have specifically criticized as undermining the law’s intent, even though it’s not always immediately clear where enforcement draws the line. This is the area with the most real-world gray zone: the law bans deliberately meaningless ranges, but proving intent behind an unusually wide range is harder than proving a range is simply missing.
Salary history questions are restricted under a separate but related NYC law
Beyond the posting-range requirement, NYC also restricts employers from asking job applicants about their salary history at prior jobs, a separate provision aimed at preventing past pay (sometimes affected by historical pay gaps) from anchoring a new offer. Job seekers sometimes conflate these two protections; they’re related in intent but are actually two distinct legal requirements, each with its own compliance obligations for employers.
Internal promotions and transfers are covered, not just external hiring
The salary range disclosure requirement applies to internal promotion and transfer postings as well as external job listings — a detail some employers miss, treating the law as an external-hiring-only requirement. An employee applying for an internal promotion at a covered employer has the same right to see a good-faith salary range as an external applicant would for the same role.
Enforcement is complaint-driven, not proactively audited at scale
NYC’s enforcement mechanism relies significantly on complaints filed with the city’s Commission on Human Rights rather than the city proactively auditing every job posting citywide for compliance — meaning genuine violations can and do go unaddressed until someone specifically files a complaint. This complaint-driven structure is part of why non-compliant postings (missing ranges entirely, or listing implausibly wide ones) still show up regularly on major job boards despite the law being in effect.
Freelancers and independent contractors fall under a different, related law
Salary transparency specifically covers employee job postings; freelance and independent contractor work in NYC is instead covered by the separate Freelance Isn’t Free Act, which focuses on written contract and timely payment requirements rather than posted rate ranges. A worker moving between freelance and salaried NYC work should understand these are two distinct legal frameworks protecting different things, not one law with two names.
Commission-based and bonus-heavy roles create real disclosure ambiguity
For roles significantly compensated through commission or performance bonuses on top of a base salary, the law requires disclosure of the base salary range but doesn’t always cleanly capture total expected compensation — a real limitation that can make a technically-compliant posting still meaningfully understate what a role could actually pay a high performer. Job seekers evaluating heavily commission-based roles should treat the posted range as a partial picture, not the full compensation story, and ask directly about commission structure during the interview process.
Multi-state employers sometimes post different ranges for different jurisdictions
Because California, Colorado, Washington, and other states have their own, sometimes differently structured, salary transparency requirements, some multi-state employers post jurisdiction-specific versions of the same role with different disclosed ranges — not necessarily reflecting real regional pay differences, but reflecting differences in what each state’s law technically requires to be disclosed. A candidate comparing postings for similar roles across states should be aware that inconsistent disclosure detail between postings doesn’t necessarily mean inconsistent actual pay.
Penalties for non-compliance are real, but civil rather than criminal
Employers found in violation of the salary transparency requirement face civil penalties through the NYC Commission on Human Rights process rather than criminal liability — a real financial consequence, though one that depends on the complaint-driven enforcement process actually catching and acting on the violation. First-time violations for employers who correct the issue promptly are sometimes treated differently than repeated or willful non-compliance, which is part of why enforcement outcomes for seemingly similar violations can look inconsistent from the outside.
Third-party job boards add their own layer of complication, since aggregated postings scraped or reposted from an original listing don’t always preserve the original salary range accurately — a job seeker relying on a board’s summary view rather than the employer’s actual original posting can end up working from outdated or mistranscribed figures without realizing it.
Next step: if you’re job hunting in NYC and see a posting with an unusually wide salary range, that’s worth a direct, early conversation with the recruiter about where a specific candidate profile would realistically land — the posted range satisfies the legal requirement, but it doesn’t obligate the employer to clarify further unless you ask.
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Photo: “Midtown skyline looking east, NYC” by Dimitry B, licensed under CC BY 2.0 (https://creativecommons.org/licenses/by/2.0/).