Cleveland pay transparency law for employers (2026): salary ranges in postings and the salary history ban

Cleveland requires employers with 15 or more employees in the city to show the salary range or scale in every formal job posting, and bars them from asking about, screening on or relying solely on an applicant's salary history. The rules are in Codified Ordinances chapter 669, enacted by Ordinance 104-2025 (passed April 28, 2025) and in force since October 27, 2025, as of November 2026. The city's Fair Employment Wage Board takes complaints, gives employers 90 days to fix a violation, and can then impose civil penalties of up to $1,000, $2,500 or $5,000 depending on past violations. Staffing agencies recruiting for a covered employer are covered too.

What is Cleveland's pay transparency law?

Chapter 669 is titled "Unlawful Discriminatory Salary Practices" and sits in Title V (Discrimination) of the Offenses and Business Activities Code, alongside the fair employment practices chapter. City Council passed Ordinance 104-2025, an emergency ordinance, as amended on April 28, 2025. Section 3 of the ordinance set a later start: the code's editor's note says the chapter "is effective on October 27, 2025." The code's history notes show no amendment since, as of November 2026. The chapter does two things in one section, 669.02: it requires a salary range or scale in postings, and it bans salary history questions. Ohio has no statewide rule on either, which our Ohio pay transparency page covers along with the other Ohio cities.

Which employers and jobs does it cover?

• Employers with 15 or more persons in Cleveland. Section 669.01(d) covers any business, nonprofit, labor organization "or any other entity," including its agents, "that employs fifteen (15) or more persons within the City of Cleveland." The count is people working in the city, not company-wide. The code does not say how to count part-time or temporary staff; counting everyone who works in the city is the cautious reading.
• Agencies acting for them. Job placement, referral and other employment agencies are employers "when such agencies operate on behalf of" a covered employer.
• The City of Cleveland is covered. Other local, state and federal government employers are not.
• Jobs in the city. An "Applicant" is someone applying for work "to be performed within the geographic boundaries of the City of Cleveland" whose application, "in whole or in part, will be solicited, received, processed, or considered" in Cleveland, whether or not they are interviewed. Both parts apply.
• Most kinds of work. "Employment" includes temporary, seasonal, part-time, contracted, contingent and commission work, and work "through the services of a temporary or other employment agency." Independent contractor work is excluded.

For remote roles, the test is where the work is done. A role performed from home in Lakewood or Columbus falls outside chapter 669 even if the hiring manager sits downtown; a hybrid role partly performed in Cleveland is the harder case, and the code does not set a minimum share of time, so post the range. A remote posting open to candidates in other states may also fall under their laws; see pay transparency for remote jobs.

What must a Cleveland job posting show?

Section 669.02(c) says employers "shall provide the Salary range or scale for potential Employment in the notification, advertisement, or other formal posting that offers the opportunity to apply for Employment." Three points follow from the definitions:

• Every external posting that invites applications. Careers pages, job boards, agency ads and social posts with an apply link all "offer the opportunity to apply." A recruiter's one-to-one message is less clearly a "formal posting"; giving the range there too costs nothing.
• A range or a scale. The code does not define either or say how wide a range may be. Unlike Columbus, Cleveland lists no "reasonableness" factors. Give a real minimum and maximum, or the published pay scale for the role; a "from" or "up to" figure gives only one end.
• Benefits count as salary. "Salary" means financial compensation "including but not limited to wages, commissions, hourly earnings, and other monetary earnings, and also includes benefits." The section does not spell out a benefits line, but a short description of benefits and any commission or bonus plan is the safer reading.

The posting rule does not apply to internal transfers or promotions, positions whose pay is set by collective bargaining, or government employers other than the City (669.02(d)). Help setting the numbers is in how to set salary ranges for job postings.

What can you no longer ask about pay?

Section 669.02(a) makes it an "unlawful discriminatory practice" for a covered employer to:

1. inquire about an applicant's salary history;
2. screen applicants on current or prior salary, including minimum or maximum pay criteria;
3. rely solely on salary history in deciding whether to offer a job or what to pay, including in negotiating a contract; or
4. refuse to hire, disfavor or retaliate against an applicant for not disclosing it.

"Inquire" is defined widely: "any direct or indirect statement, question, prompting or other communication, orally or in writing, personally or through an agent," and any search of publicly available records about the applicant. Note the word "prompting." Telling the applicant the proposed pay is not an inquiry.

What stays allowed: discussing the applicant's expectations, "including but not limited to, unvested equity or deferred compensation" they would forfeit by resigning (669.02(b)); objective productivity measures such as revenue or sales, which are not salary history; background checks and verification of non-salary information, provided any pay that turns up is not "solely relied upon"; a "voluntary and unprompted disclosure"; rehires where the employer already holds the applicant's past pay; and actions under a law that specifically authorizes relying on salary history. Cleveland bans relying "solely" on pay history, a narrower test than the outright bans in Cincinnati and Toledo. Wording that stays on the right side is in salary expectation questions.

How does a complaint work, and what are the penalties?

The Fair Employment Wage Board (FEWB), the board that already administers Cleveland's living wage and wage theft laws, runs chapter 669 (669.03). The steps in 669.04:

1. Complaint within 180 days. "Any person" may file a written complaint describing the violation, naming the respondent (the employer, the person who committed the violation, or both) and attaching documentation such as application materials or a link to the posting. A signature and contact details are optional. The city takes complaints through its unlawful salary complaint page.
2. Review within 90 days. The board considers the complaint at its next meeting and no later than 90 days after receiving it. If it has neither documentation nor the complainant's identity, the board sends the respondent a copy and a notice of the rules within 10 days and takes no further action. A screenshot of a posting without a range is documentation in our reading, so an anonymous complaint can still go forward.
3. Finding and notice. Otherwise the board decides, by a preponderance of the evidence, whether a violation occurred. If it did, the board sends the respondent the complaint, the basis for its finding and a proposed resolution within 10 days, then tries "education, conference, conciliation, and persuasion." Its rules (Article VII) set out the hearing: each side presents, the board decides at once or within 30 days, and the decision goes to the parties within 15 days.
4. 90 days to cure. The complaint counts as resolved if, within 90 days of receiving it, the respondent corrects its "processes, policies, and/or application materials" and gives the board "a credible plan to commit no further violations."
5. Civil penalty. If not resolved, the board may assess a penalty under 669.99: up to $1,000 with no prior violations in the five years before the complaint, up to $2,500 with one, and up to $5,000 with two or more. The caps are adjusted each February 1 in line with the CPI-U.
6. Appeal. A penalty can be appealed to the Director of Finance within 30 days, and that decision to the Board of Zoning Appeals within 30 days. A penalty unpaid after 30 days can be collected through a civil action (669.05).

Chapter 669 does not give applicants a private lawsuit, and it requires no workplace poster or applicant notice; the FEWB's resources page lists its rules and its living wage and wage theft materials, and no pay transparency poster, as of November 2026. How Cleveland's fines compare with other cities and states is on pay transparency penalties by state.

Does Ohio law change any of this?

No. Ohio's 2017 labor preemption statute, R.C. 4113.85, reserves hours, scheduling, work location and fringe benefits to employer policy; it does not mention pay disclosure or hiring questions. Cities act under the home rule power in Article XVIII, Section 3 of the Ohio Constitution, for regulations "not in conflict with general laws." The Legislative Service Commission's status report for the 136th General Assembly, current to October 30, 2026, lists no bill on pay ranges, salary history or preempting city rules on them. Cleveland's rule is therefore the stricter one. State and federal equal pay law still applies: R.C. 4111.17, and the EEOC's Compliance Manual says "Prior salary cannot, by itself, justify a compensation disparity." The federal contractor pay transparency rule (41 CFR 60-1.35) is gone, removed effective October 26, 2026 by 91 FR 54444.

What do staffing agencies and recruiters need to do?

• Check the client, not just the agency. An agency is an employer under chapter 669 when it operates on behalf of a covered employer, so the trigger is the client's 15 or more people in Cleveland. For the agency's own internal hires, its own headcount in the city decides.
• Both postings need the range. The client's careers page and the agency's job board ad are each a "formal posting." Get the range in writing at intake and put the worker's pay rate in the ad, never the bill rate; see pay transparency for staffing agencies.
• Temporary assignments count. Work "through the services of a temporary or other employment agency" is employment, so temp and temp-to-hire ads for Cleveland worksites need a pay range too.
• Either can be named. A respondent is "the Employer and/or person" alleged to have violated the section, so a complaint about an agency ad can name the agency, the client or both.
• Keep pay history out of the file. Remove current-pay fields from agency applications and intake forms, use a submittal template without a current-salary line, and keep pay off reference calls.

A copy-ready Cleveland posting line and pay script

CLEVELAND JOB POSTING: PAY SECTION (example figures)

Pay: $24.00 to $29.00 per hour ($49,920 to $60,320 a year at 40 hours)
Bonus or commission: [describe the plan, or "None"]
Benefits: [medical, dental and vision; 401(k) match; paid time off]
Location: [address in Cleveland, or "hybrid, at least X days a week
in our Cleveland office"]
We do not ask applicants about their current or past pay.

RECRUITER SCRIPT
Opening the topic:
  "This role pays $24 to $29 an hour plus benefits. What are you
  looking for, and would you give anything up by leaving, like an
  unvested bonus?"
If the candidate starts to share current pay:
  "You don't need to tell me that. We set offers from the range."
If the client asks for current pay:
  "Cleveland's chapter 669 covers us both for this role, so I don't
  collect it. Her expectation is $27, inside your range."

Cleveland chapter 669 at a glance

A Cleveland checklist

1. Count the employer's people working in Cleveland; at 15 or more, chapter 669 applies to jobs performed in the city.
2. Put a real range or scale, plus a short benefits and incentive line, in every external posting, including agency and job board versions.
3. Strip salary history questions from applications, screening scripts and intake forms.
4. Ask about expectations and forfeited pay only, and keep volunteered figures out of notes; see what not to write in interview notes.
5. If a complaint arrives, fix the posting or form within 90 days and send the board a written plan.

More Ohio rules: salary history bans in Ohio, hiring employees in Ohio and, for other states, pay transparency laws by state.