Colorado Pay Transparency Law: What Employers Must Disclose

The Posting Is Due Friday — Does It Have a Salary Range?

Picture this: your company just opened a remote software-developer role. You draft the posting, pick your job boards, and schedule it to go live Friday morning. An hour before launch, someone in your team flags it — Colorado's Equal Pay for Equal Work Act requires a salary range on that posting, and you're hiring in Denver. You have a number in your head, but nothing documented, no methodology written down, and no idea how to translate "somewhere around $120K" into a defensible range that will hold up if the Colorado Civil Rights Division comes knocking.

Colorado was the first state in the country to require employers to post salary ranges on job listings, and it remains one of the most actively enforced. As of July 1, 2024, the Colorado Department of Labor and Employment (CDLE) had logged 1,634 complaints and assessed $238,000 in fines under the law (Trusaic citing Colorado CDLE, 2024). That enforcement record is a signal: CDLE investigates complaints, and it does so at scale.

By the end of this article you will know exactly what the Colorado pay transparency law requires you to post, who it covers, what the penalty exposure looks like, and how to construct a salary range anchored in publicly available wage data that you can actually defend.

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What the Colorado Equal Pay for Equal Work Act Requires

The Colorado Equal Pay for Equal Work Act (EPEWA), enacted as SB19-085 (Colorado General Assembly, 2019) and effective January 1, 2021, is the foundation of the state's colorado pay transparency law framework. It was substantially amended effective January 1, 2024. The statute is administered and enforced by the CDLE.

At its core, EPEWA requires employers to include three elements in every job posting for a Colorado role:

1. The hourly rate or salary range — a minimum and a maximum compensation figure that reflects what the employer in good faith believes it might pay for the position. A single number (e.g., "starts at $65,000") does not satisfy the requirement; you need a spread.
2. A general description of any bonuses, commissions, or other compensation the position may be eligible for.
3. A general description of all employment benefits offered, including health, dental, vision, retirement, PTO, and similar benefits.

"Good faith" is doing real work in that first requirement. The CDLE has interpreted it to mean the range must reflect what the employer actually intends to pay — not an artificially wide band designed to avoid the spirit of the law. A range of $30,000–$300,000 for a single individual-contributor role is unlikely to survive scrutiny.

Always confirm the current rule and any guidance updates directly with the CDLE at cdle.colorado.gov or with legal counsel before relying on any interpretation — requirements and enforcement guidance evolve.

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Who Must Comply With the Colorado Pay Transparency Law

The EPEWA applies to any employer with at least one Colorado employee, regardless of where the employer's headquarters or primary operations are located (Colorado General Assembly, SB19-085, 2019; amended Jan 1, 2024). That threshold is deliberately low.

Critically, it also applies to remote job postings — even if the posting does not explicitly say it's open to Colorado residents, CDLE has taken the position that if a remote role could be filled by a Colorado-based applicant, the posting must comply. Early in the law's enforcement history, some national employers attempted to exclude Colorado from remote postings rather than comply; the CDLE's enforcement posture has made that workaround legally risky and operationally awkward.

If your company has even one employee who works from Colorado — or you are open to hiring someone who would — the colorado job posting requirements apply to you.

For context on how Colorado's coverage compares to other states, see our pay transparency laws by state overview.

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Penalty Exposure: What Non-Compliance Costs

The EPEWA establishes civil fines of $500 to $10,000 per violation, with each non-compliant posting treated as a separate violation (Colorado General Assembly, SB19-085, 2019). That structure matters: if you post the same role on LinkedIn, Indeed, ZipRecruiter, and your company careers page without a range, that may be treated as four separate violations — not one.

Penalties escalate for repeat violations. The CDLE has demonstrated it will act on complaints: the 1,634 complaints and $238,000 in fines assessed as of July 1, 2024 (Trusaic citing Colorado CDLE, 2024) represent real enforcement activity, not theoretical exposure.

The tone here is informational, not alarmist: most employers who face scrutiny do so because a posting slipped through without a range, not because they built a range in bad faith. The defensible path is a documented range with a documented methodology — a point we return to below.

For a broader look at how penalty structures work across jurisdictions, see pay transparency penalties explained.

Always verify the current penalty schedule and enforcement guidance with the CDLE (cdle.colorado.gov) or qualified legal counsel before acting. Figures cited above are drawn from the statute and CDLE-reported enforcement data; rules and enforcement posture can change.

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How to Build a Defensible Salary Range for Colorado Roles

A defensible range under the colorado equal pay act is not simply a number you feel comfortable with — it is a range you can explain to an attorney, a job candidate, or a CDLE investigator. That explanation needs to reference a data source, a methodology, and a rationale for the spread.

Here is the framework:

Step 1 — Anchor to BLS OEWS Colorado State Data

The Bureau of Labor Statistics Occupational Employment and Wage Statistics (OEWS) program publishes annual wage estimates for over 800 occupations at the national, state, and metro-area level (BLS, May 2025). Colorado state-level estimates are available at bls.gov/oes. The most recent national release was the May 2025 OEWS, published May 15, 2026 (BLS, 2026); confirm which release year is live for Colorado-specific data at bls.gov/oes when you build your range.

BLS OEWS data is reported at five percentiles: the 10th, 25th, 50th (median), 75th, and 90th. Those percentiles are the legitimate, publicly defensible anchor for a range methodology.

Percentile means the wage below which a given share of workers in that occupation and geography earn. The 50th percentile (the market median) is the midpoint of the wage distribution for that role in Colorado. The 25th percentile is the wage below which a quarter of workers in that occupation earn; the 75th is the wage below which three-quarters earn.

Important: the verified-data library underlying this article does not carry specific Colorado state-level percentile figures by occupation — the BLS OEWS national figures in the library are national estimates and should not be substituted for state figures without verification. For Colorado-specific salary-range construction, pull the current Colorado OEWS data directly from bls.gov/oes. The national medians cited below are illustrative anchors only.

For example, the national BLS OEWS median for Software Developers (SOC 15-1252) is $133,080, with a 10th percentile of $79,850 and a 90th percentile of $211,450 (BLS OOH, May 2024). The Colorado figure will differ — Denver in particular has a distinct tech-labor market. Pull the Colorado or Denver-Metro OEWS estimate for the accurate anchor.

For guidance on how geographic location affects appropriate range anchors, see geographic pay differentials explained.

Step 2 — Set the Range Spread

Range spread is how wide the pay band is, expressed as a percentage of the midpoint (or, in some conventions, of the minimum). A spread of 50% around a midpoint means the minimum is 75% of the midpoint and the maximum is 125% of the midpoint.

Typical spread conventions by role type:

• Narrow-scope individual contributors (e.g., customer service, data entry): 30–40% spread
• Mid-scope professional roles (e.g., accountants, HR generalists, project managers): 40–60% spread
• Senior professional / management roles (e.g., marketing managers, HR managers): 60–80% spread

These are methodological conventions, not legal requirements. The EPEWA requires a "good faith" range — not a specific spread — but a documented spread rationale is exactly the kind of methodology documentation that protects you in an enforcement inquiry.

For a detailed walkthrough of how to set a range spread, see how to build a salary range.

Step 3 — Document the Methodology

This step is where most small employers fall short. The CDLE does not require you to publish your methodology in the job posting — but if you receive a complaint, your ability to demonstrate that your range was constructed in good faith depends on having something on paper.

Minimum documentation to retain:

• The BLS OEWS source (dataset name, release year, geography, SOC code)
• The percentile or percentiles used as anchors
• The spread convention applied and the rationale
• Who approved the range and when
• The job posting itself

Keep this documentation for as long as you retain the posting. The Illinois parallel is instructive: Illinois HB3129 (effective Jan 1, 2025) requires employers to retain pay-scale and posting records for five years (Greenberg Traurig / Illinois DOL, 2024). Colorado's EPEWA does not currently carry a parallel five-year statutory retention requirement, but CDLE guidance and employment-law best practice both support retaining this documentation for the duration of any plausible complaint window. Confirm the current Colorado retention expectation with the CDLE or counsel.

For a structured checklist of what to include in a compliant posting, see what to include in a salary range posting.

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Multi-State and Remote Roles: Colorado's Reach

The colorado salary disclosure requirement creates a practical compliance challenge for companies that post a single national remote role across multiple job boards. The posting must comply with Colorado's requirements if it is open to Colorado applicants — which, for a truly remote role, it almost certainly is.

That same posting may also trigger obligations in other states. As of 2026, 16 states plus Washington D.C. mandate salary disclosure in job postings, with Delaware joining in 2027 (Paycor / Nesco Resource, 2026). A single remote posting that reaches applicants in Colorado, New York, California, and Washington must satisfy the most demanding requirements of all four jurisdictions simultaneously.

The practical approach is to build the most-disclosure version of your posting — range + benefits + bonus/commission language — and apply it universally. It costs nothing extra to be compliant everywhere when you are already compliant with Colorado.

For a jurisdiction-by-jurisdiction comparison, see the pay transparency resource hub.

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What a Compliant Colorado Posting Looks Like

A compliant posting for a mid-level accounting role in Denver might read:

Compensation: $72,000–$90,000 annually, based on experience and qualifications. This role is eligible for an annual performance bonus of up to 10% of base salary.

Benefits: Medical, dental, and vision insurance (employer covers 80% of premium); 401(k) with 4% employer match; 15 days PTO accruing from day one; 10 paid holidays; remote-work stipend of $75/month.

That structure satisfies all three EPEWA disclosure elements: a genuine salary range, a description of additional compensation, and a description of benefits. It is specific enough to constitute a "good faith" range — anchored, in this example, near the national BLS OEWS median for Accountants and Auditors (SOC 13-2011) of $81,680 (BLS OOH, May 2024) — with a spread that reflects a mid-scope professional role. For a Colorado posting, you would pull the Colorado state-level OEWS figure from bls.gov/oes to set the actual anchor.

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Build Your Colorado Range With Documented Methodology

Colorado's EPEWA has been in effect since 2021, amended in 2024, and actively enforced. The barrier to compliance is not legal complexity — the requirements are clear. The barrier is having a documented, repeatable process for building ranges that you can defend.

The Pay Transparency Compliance Kit includes a state-by-state compliance checklist (covering Colorado's current EPEWA requirements), a BLS OEWS range-building worksheet, a methodology documentation template, and a compliant job-posting template formatted for Colorado. It is designed for HR generalists and people-ops leads who need a defensible compliance workflow without a dedicated compensation analyst.

If you're building ranges at scale across multiple roles or multiple states, Salary Range Builder starts at $199/month and generates BLS-anchored, documentation-ready salary ranges with a methodology audit trail — same-day activation, no onboarding call required.

Whatever tools you use, the core principle is the same: build the range before you write the posting, document how you built it, and keep that documentation somewhere you can find it when the CDLE comes looking.