SHRM26 Debrief · Compensation & Benefits · #2286

Pay Reporting Road Trip: A Coast-to-Coast Guide to Transparency & Compliance—Now with a European Detour

with Krystal Welland

& Joanna Colosimo

▶ Watch on the SHRM portal ~87 min, distilled

pay transparencypay reportingpay equity

"Colorado actually out-Californianed California."

What it was about

Pay transparency and pay reporting laws have exploded into a fast-moving, state-by-state (and now global) patchwork that goes far beyond posting salary ranges. Employers need a unified, nationwide (and increasingly international) compliance strategy backed by strong job architecture and defensible pay data, because transparency requirements expose underlying compensation and pay-equity problems that used to stay hidden.

By the numbers

81 cents on the dollar

women's earnings relative to men nationally

65 cents on the dollar

African American women's earnings relative to men

approximately 58 cents on the dollar

Hispanic women's earnings relative to men

Key notes

Distinguish pay transparency (job posting disclosure requirements), pay reporting (submitting aggregate or line-by-line pay data to the state), and pay equity (whether employees are actually paid fairly) — compliance with one does not mean compliance with the others.
Audit job posting practices everywhere you recruit, hire, or allow remote work, not just in your headquarters state, since laws like Washington's can apply based on where the work could be performed.
Pressure-test your compensation structure so you can produce a defensible, meaningful pay range (not absurdly wide like $60,000-$225,000 or absurdly narrow like $71,000-$72,000) for every open role.

The contrarian takeWaiting for regulatory certainty before acting is the wrong strategy. The speakers argue employers (citing Procter & Gamble's approach) should get ahead of EU Pay Transparency Directive obligations now, even though most member states haven't yet transposed the directive and full reporting isn't due until 2027, because day-one obligations like salary disclosure and the employee 'right to information' are already active.

Take this back Monday

Do this for your team

Audit every open job posting for pay ranges that are defensible, not absurdly wide or narrow, in every state where you recruit.

Say this in your next leadership meeting

Pay transparency, pay reporting, and pay equity are three separate obligations — being compliant on one doesn't mean we're covered on the others.

Watch out for

Conflating pay disclosure/posting compliance with the separate obligation of pay data reporting once an employee-count threshold is hit (a mistake many California employers made).
Assuming a state-by-state contained-risk approach (e.g., 'just focus on California') is still viable given how fast the patchwork of laws has grown.
Posting meaninglessly wide or artificially narrow salary ranges that regulators are starting to crack down on as not 'good faith.'

Fun fact · Krystal Welland

Krystal Welland is a statistician, not a lawyer, yet Colorado Law Week named her an "Outstanding Legal Professional."

If this landed, see these

↳ Go deeperFrom Toronto to Brussels and Everything In Between: Navigating the New Era of Global Pay TransparencyTakes the European detour and turns it into a full global compliance roadmap.⇄ The counterpointFair Pay, Lean Resources: Compensation Strategies for Small & Midsize HR TeamsArgues you don't need P&G-scale infrastructure: a lean team can still build defensible pay.✦ The unexpected oneWhen Employee Relations Isn't Enough: A CLEAR Framework for Protected Class InvestigationsThe same documentation-and-neutrality logic that keeps investigations defensible applies to pay data too.