Compliance Conundrum: Complying with the New Cleveland, Ohio Pay Transparency Law Effective October 27, 2025

The fourth city in Ohio which passed a pay transparency law is set to go into effect on October 27, 2025. Cleveland adopted Ordinance 104-2025 in April 2025 with the intent to close the gender wage gap by making it unlawful and discriminatory for an employer to: 

• Inquire about an applicant’s salary history 
• Screen applicants based on their current salary or salary history, including requiring that an applicant’s salary history satisfy minimum or maximum criteria 
• Rely solely on an applicant’s salary history in deciding whether to offer employment to the applicant or in determining the salary for the applicant during the hiring process, including the negotiation of an employment contract 
• Refuse to hire or otherwise disfavor, injure, or retaliate against applicants for not disclosing their salary history. 

Key Provisions of the Cleveland Ordinance 

Here are a few key provisions of the Ordinance of which employers should be aware:  

• Covered employer in the ordinance is an entity, including any agent of the entity, which employs fifteen (15) or more persons within the City of Cleveland. “Employer” includes job placement and referral agencies and other employment agencies when such agencies operate on behalf of an entity that otherwise meets the definition of an employer under the Ordinance. The definition includes the city of Cleveland but no other local, state or federal government units.  
• Salary means a person’s financial compensation in exchange for labor, including but not limited to wages, commissions, hourly earnings, and other monetary earnings, and also includes benefits.  
• Salary history is defined as an applicant’s current or prior salary. It does not include any objective measure of an applicant’s productivity such as revenue, sales, or other production reports.  
• Exemptions – the ordinance does not apply to applicants for internal transfer or promotion with their current employer, applicants re-hired by the employer, a voluntary, unprompted disclosure of salary history by an applicant, positions where the salary is established under collective bargaining, or any attempt by an employer to verify non-salary related information and the applicant’s salary history is disclosed although in that case, such disclosure may not be relied upon for determining salary.