Colorado’s Pay Transparency Law (EPEWA) in 2026

HR / Workplace

By:  Kim Adamson

Pay transparency laws are rapidly reshaping hiring, compensation, and compliance practices across the United States. Pay transparency laws are designed to reduce wage gaps, promote equitable hiring, and provide employees with clearer compensation expectations. States like California, Colorado, Hawaii, New York, and Washington require employers to include pay ranges in job advertisements.  Several cities, including New York City, Jersey City, and Seattle, also have their own ordinances.  Colorado is one of the most influential states in this movement and introduced the nation’s first pay transparency law with some of the most comprehensive and enforceable requirements. This article highlights Colorado’s pay transparency law.

Brief History of Colorado’s Equal Pay for Equal Work Act (EPEWA)

Colorado’s pay transparency requirements were established under the Equal Pay for Equal Work Act (EPEWA), which became effective January 1, 2021, and introduced pay transparency in job postings, equal pay protections, and recordkeeping requirements. The EPEWA was amended and expanded effective January 1, 2024, which expanded the definition of “job opportunity” and added requirements to post all job opportunities, introduced post‑selection notices, clarified career progression rules, added rules for acting, interim, and temporary (AINT) roles, and expanded obligations for remote‑eligible roles, as well as strengthened enforcement and clarified penalties. On January 1, 2025, Colorado’s Department of Labor and Employment (CDLE) issued additional rules and interpretive guidance to strengthen enforcement of the EPEWA to better align with Colorado’s Wage Protection Rules. The amendment required employers to not only disclose pay ranges, but also bonus opportunities, commission structures, and potential promotion timelines; clarified that remote positions performed in Colorado must comply with the EPEWA, including postings by out-of-state employers; increased record-keeping requirements (pay history records must be retained for at least 10 years and must include pay rate changes, job descriptions and rationale for compensation); added stronger anti-retaliation protections, higher penalties for employers who fail to comply with wage transparency rules (ranging from $500 to $20,000 per violation), and public reporting and investigation by the CDLE for repeated violations.

Below are the key requirements of Colorado’s EPEWA:

All Job Postings, Internal or External, Must Disclose the Following:

  • The pay range (hourly or salary) must accurately reflect the lowest to highest compensation the employer believes it will offer, helping employers maintain credibility and avoid potential violations.
  • A list of all major benefits (health, dental, vision, retirement, PTO, etc.) Minor benefits, such as employee discounts, are not required.
  • Any bonuses, commissions, or incentives
  • How candidates apply and the application deadline. For positions where the employer accepts ongoing applications, no deadline is required.

Notify All Employees of Job Opportunities

Every job opportunity, current or anticipated, must be posted for all employees before a hiring decision is made.  External postings are not required, but employers must provide internal notice of all job opportunities.  A “job opportunity” includes any vacancy for which the employer is considering or interviewing candidates.

Disclose Who Was Selected for the Role

After filling a role, employers must inform employees of the selected candidate within 30 days of the candidate’s start date.

Provide Transparency in Career Progression

Career progression does not meet the Act’s definition of job opportunities and does not require posting under the Act. However, employers must outline how employees can advance within defined career paths.

Non-competitive promotions are generally classified as career progression that occurs when an employee meets pre-established objective criteria, such as tenure, obtaining certifications, skill attainment, and other performance benchmarks.

Career development is not a legal classification under the Act and is generally considered part of an employee’s career progression, which, as stated, does not require posting.   Career development includes opportunities that prepare employees for future roles, such as training, skill-building, mentorship, and long-term growth planning.

Acting, Interim, and Temporary (“AINT”) Roles

Colorado’s Act provides specific rules for acting, interim, or temporary (referred to as “AINT”) position assignments that do not require advance posting, provided they meet the state’s criteria for temporary coverage. The Act recognizes that employers sometimes need to fill a position quickly to maintain business operations. Employers may place an employee in an AINT role without announcing the opportunity in advance if the assignment is expected to last no more than 6 months and is used solely to ensure business continuity. However, if the AINT role later becomes a permanent position, or if the temporary assignment extends beyond the six-month limit, the employer must post the job opportunity in compliance with the Act’s requirements.

Remote Worker Roles

If a Colorado-based or remote worker could perform a job, the posting must comply with Colorado’s transparency rules (even if the employer is not based in Colorado). Employers should not exclude certain states from remote postings to avoid compliance with Colorado’s Act or other states’ transparency laws.

Record Keeping Requirements

Employers are required to maintain detailed records for at least 10 years regarding wage histories, job descriptions, posting and notice records, and rationale for compensation.

Employers can strengthen compliance and reduce risk under Colorado’s EPEWA by taking the following steps:

  • Establish clear procedures and standardized templates to ensure all job postings include required elements such as pay ranges, benefits, and application deadlines. Update internal systems (ATS, HRIS, and related tools) to support consistent disclosures.
  • Refine hiring and posting workflows so that all employees receive timely notice of job opportunities, including those that may be remote-eligible or open across multiple locations.
  • Document compensation policies for remote, hybrid, and multi-state roles, ensuring pay decisions are consistent, transparent, and aligned with organizational guidelines.
  • Train hiring managers and recruiters on disclosure requirements and effective communication of pay information throughout the hiring process.
  • Conduct regular pay range audits to confirm ranges remain accurate, competitive, defensible, and aligned with internal equity.
  • Maintain thorough records in accordance with updated EPEWA requirements to support compliance and provide documentation in the event of an inquiry or claim.
  • Stay current on regulatory developments and update internal policies, procedures, and communication practices as Colorado continues to refine its pay transparency rules.

Pay transparency is no longer optional in Colorado—or in many other states, counties, and cities across the U.S. It has become a defining element of employment practices in 2026 and beyond. Colorado’s approach, in particular, signals the direction of the national landscape: a movement toward greater openness, fairness, and accountability in compensation. For employers, pay transparency is not just a compliance requirement, it is a strategic advantage. Embracing it can strengthen trust and commitment, elevate employee morale, advance equity, modernize compensation practices, and ultimately help organizations attract and retain top talent.

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