We have learned that the Colorado Department of Labor & Employment anticipates publishing next week additional guidance on the Equal Pay Transparency rules’ promotional posting requirements.  In response to a request for clarification around in-line promotions, the CDLE informed us: We believe your questions will be addressed by a forthcoming Interpretive Notice & Formal Opinions (“INFO”), which we expect to release next week. In addition to addressing your questions, this INFO will provide other clarification…

The deadline for employers to comply with California’s pay data reporting requirement (Senate Bill 973) and submit pay data to the Department of Fair Employment and Housing (DFEH) is March 31, 2021. The DFEH has launched an information page that provides needed clarity on certain obligations and has issued additional guidance on the pay data report’s contents — largely confirming certain assumptions and clarifying other requirements. Submission will resemble EEO-1 Reports. Employers will…

As anticipated, the Colorado Department of Labor and Employment has released final administrative rules implementing the new Colorado Equal Pay for Equal Work Act.  The final rules reflect comments received in writing and during a live, virtual, public hearing held on November 2, 2020. Of primary concern to employers were the proposed rules’ job posting requirements for promotional opportunities and compensation disclosure.  The good news is the final rules are dramatically reduced in scope…

At the end of California’s 2020 legislative session, Governor Newsom signed Senate Bill 973 (SB 973), which created pay data reporting requirements for employers starting in March 2021. However, the new legislation left some uncertainty for employers in several areas. The Department of Fair Employment and Housing (DFEH) promised in mid-October that it would be issuing a Frequently Asked Questions page to assist with compliance. On November 2, it did so—at least partially.  The current…

On November 2, 2020, the Colorado Department of Labor and Employments’ Division of Labor Standards and Statistics held a public hearing to solicit comments about Colorado’s proposed Equal Pay Transparency Rules.  The proposed rules will implement Colorado’s New Equal Pay for Equal Work law that goes into effect January 1, 2021.  The hearing focused on the rules concerning pay information in job postings and announcements of promotional opportunities.  The Division is continuing to collect written…

In a continued effort to reduce gender and racial pay gaps, on September 30, 2020, California Governor Gavin Newsom signed into law Senate Bill 973, which creates massive pay reporting requirements for employers.  In 2021, certain California employers will be required to submit annual information on its employees’ pay data by gender, race, and ethnicity to the state’s Department of Fair Employment and Housing (DFEH).  A similar bill was introduced last year (following the EEOC’s court…