Ohio employers are navigating an evolving patchwork of pay laws. Without a statewide mandate, local jurisdictions are taking matters into their own hands, introducing salary history bans, pay disclosure requirements, and transparency measures that reshape hiring practices. Cincinnati, Columbus, and Toledo have already implemented salary history bans and wage disclosure requirements, and now Cleveland is poised to follow suit, adding another layer of complexity for employers in 2025.
At the same time, Ohio is introducing a new pay stub disclosure requirement, which will mandate that employers provide employees with detailed wage statements. For businesses operating across multiple jurisdictions, staying ahead of these localized pay equity laws is essential to mitigating compliance risks and avoiding costly missteps.
Ohio’s New Pay Stub Disclosure Law
With the passage of Section 4113.14 of the Ohio Revised Code, the state is standardizing how employers communicate pay details to their workforce. Effective April 9, 2025, the law requires all employers to provide written or electronic wage statements detailing:
- Employee’s name and address
- Employer’s name
- Total gross wages earned
- Total net wages paid
- Itemized additions and deductions
- Pay period covered and date of payment
- For hourly workers: total hours worked, hourly rate, and overtime hours
Failure to comply could trigger employee complaints to the Ohio Director of Commerce, leading to public posting requirements that may expose employers to reputational risk.
While this law does not mandate pay transparency, it adds a new layer of wage accountability for employers—complementing but distinct from the salary history bans and disclosure requirements already in effect in Ohio’s largest cities.
Cincinnati: Pay Transparency and Salary History Ban
Cincinnati led the charge when it passed Ordinance No. 83 in March 2020, implementing a salary history ban and pay range disclosure requirement. The law applies to employers with 15 or more employees and prohibits:
- Inquiring about an applicant’s salary history
- Screening candidates based on prior wages
- Refusing to hire applicants who decline to disclose their past earnings
However, Cincinnati’s approach stops short of requiring upfront salary disclosures in job postings. Instead, employers must provide pay ranges upon request—but only after extending a conditional job offer.
This regulation aims to prevent historical pay disparities—particularly for women and marginalized groups—from perpetuating through the hiring process. Violators face potential lawsuits from affected applicants, who may seek compensatory damages and legal fees.
Columbus: Expanding Pay Equity in 2024
Columbus took the salary history ban a step further by introducing Ordinance 0709-2023, which took effect March 1, 2024. Designed to promote pay equity and eliminate systemic discrimination, the law prohibits employers with 15 or more employees from:
- Salary history inquiries at any stage of hiring
- Using past pay to determine job offers or compensation
- Accessing public records to obtain salary history
- Retaliation against applicants who refuse to disclose past earnings
Unlike Cincinnati, Columbus enforces monetary penalties for noncompliance—ranging from $1,000 to $5,000 per violation—and allows applicants to file complaints with the Columbus Community Relations Commission within six months of an alleged violation.
While salary history inquiries are banned, employers may still ask applicants about their salary expectations, providing some flexibility in pay negotiations.
Toledo: Pay Equity With a Transparency Twist
Toledo’s Pay Equity Act, which went into effect on June 25, 2020, is one of the most robust salary history bans in the state—barring not just inquiries, but also the use of salary history in hiring and pay-setting decisions.
The law applies to private employers with 15 or more employees, prohibiting:
- Asking about salary history
- Screening candidates based on past pay
- Setting minimum or maximum salary thresholds based on prior earnings
- Retaliating against applicants who do not disclose their past wages
Like Cincinnati, Toledo requires employers to disclose pay ranges upon request after extending a conditional job offer. However, Toledo’s law lacks a clear definition of “pay scale,” creating uncertainty about what employers must disclose.
Employers who violate Toledo’s ordinance risk private lawsuits from job applicants, with potential liability for damages.
Cleveland: A New Pay Transparency Law on the Horizon?
Cleveland is poised to follow suit with a proposed Salary History Ban Ordinance (Ordinance No. 104-2025). If enacted, the law would align the city with existing pay equity laws in Cincinnati, Columbus, and Toledo, while also introducing new transparency measures.
If Passed, the Law Would:
- Prohibit Employers From:
- Asking about an applicant’s salary history
- Using past earnings to determine a salary offer
- Retaliating against applicants who refuse to disclose salary history
- Require Employers To:
- Disclose salary ranges in job postings
- Comply with the ordinance within 180 days of enactment
Cleveland’s proposed ordinance would apply to employers with 15 or more employees, including temporary, part-time, and commission-based jobs (excluding independent contractors).
Upon its possible effective date, the law will be enforced by the Fair Employment Wage Board (FEWB), with civil penalties ranging from $1,000 to $5,000, depending on the employer’s history of violations.
What This Means for Employers
Ohio’s patchwork approach to pay equity means that multi-city employers must adopt localized hiring strategies. Companies should act now to:
- Update hiring policies: Remove salary history questions from applications and interviews.
- Train HR teams: Ensure managers understand city-specific compliance obligations.
- Establish salary bands: Prepare for disclosure requirements by defining pay ranges proactively.
- Audit payroll and pay stubs: Ensure compliance with Ohio’s new 2025 wage disclosure law.
Looking Ahead: The Growing Momentum of Pay Transparency
Could Cleveland’s push for pay transparency spark momentum for a statewide measure? Rather than viewing these developments as compliance hurdles, businesses should see them as an opportunity to build trust and equity in the workplace.
Ohio is not alone in adopting pay equity measures. Across the U.S., salary history bans and pay transparency laws are becoming the norm rather than the exception. As employee expectations shift and regulatory scrutiny increases, companies that proactively implement fair pay practices will not only mitigate legal risks but also strengthen their reputation as employers of choice.