Workforce Bulletin

In April 2025, the City of Cleveland approved Ordinance No. 104-2025 (the “Ordinance”), which will impose a salary history ban and create a pay disclosure requirement for employers starting Monday, October 27, 2025. The latter provision – the first in the Buckeye State to require affirmative disclosure of wages or salary ranges for advertised positions – distinguishes this Ordinance from pay equity laws already enacted in other Ohio municipalities. The new pay equity measures will apply to the City of Cleveland and private employers with at least 15 employees working within Cleveland, including job placement and referral agencies working on behalf of another employer. We discuss both requirements below.

Salary History Ban

Like similar laws in Cincinnati, Columbus, and Toledo, the Ordinance broadly prohibits covered employers from:

• Asking about an applicant’s current or prior salary, including wages, commissions, hourly earnings, and any other monetary earnings, as well as benefits (collectively, their “salary history”);
• Screening applicants based on their salary history (including requiring an applicant’s former salaries to meet a threshold);
• Relying solely on an applicant’s salary history when deciding whether to make an offer of employment or determining their compensation; and
• Refusing to hire or otherwise retaliating against an applicant for not disclosing their salary history.

On July 20, 2025, Ohio will officially become one of the first states to allow employers to provide digital—rather than physical—copies of certain labor law notices required under Ohio law.  Specifically, under changes imposed by Senate Bill 33 (SB 33), Ohio will soon allow employers and businesses to post the following Ohio notices digitally:   

• Minor Labor Laws
• Minimum Fair Wage Standards Law
• Civil Rights Law
• Prevailing Wage Law
• Workers’ Compensation Law
• Public Employment Risk Reduction Program Law  

Beginning April 9, 2025, Ohio employers will be legally required to give employees access to their paystubs. Citing transparency, accountability, and fairness in the workplace, the Ohio General Assembly unanimously passed the the Paystub Protection Act (PPA),  which requires Ohio employers to issue paystubs, either electronically or via hard copy, to all employees on regular paydays that include the:

• Names of the employee and employer;
• Employee’s address;
• Employee’s total gross wages during the pay period;
• Employee’s total net wages during the pay period;
• Amount and purpose of each addition or deduction to wages; and
• Dates of the pay period.

For hourly employees, the following three additional items are required:

• Total hours worked;
• Hourly rate; and
• Hours worked in excess of 40 hours in one workweek.

Columbus has joined Toledo, Cincinnati, and a number of states and locales around the country, in banning employers from asking job applicants about their salary history.

Effective March 1, 2024, covered employers in Ohio’s capital will be prohibited from:

• inquiring about an applicant’s salary history,
• screening applicants based on their salary history,
• relying solely on salary history when deciding whether to offer an applicant employment or determining their compensation, and
• retaliating against applicants for not disclosing their salary history.

Salary History

Currently, neither the federal Fair Labor Standards Act (FLSA) nor the Equal Pay Act (EPA) prohibit employers from screening applicants based on prior salary, requesting an applicant’s salary history, or conditioning an applicant’s employment on providing their salary history. However, salary history bans, which are intended to eliminate the perpetuation of discriminatory pay disparities, have become increasingly common both at the state and local level. As of April 2023, more than 40 states and localities have adopted some form a salary history ban.

Ohio’s minimum wage will increase to $9.30 per hour for non-tipped employees and $4.65 per hour for tipped employees, effective January 1, 2022.  This new minimum wage will apply to employees of businesses with annual gross receipts of more than $342,000 per year.

For employees at smaller companies with annual gross receipts of $342,000 or less per year, and for 14- and 15-year-olds, the minimum wage continues to be the federal rate of $7.25 per hour.

As a reminder, employers should update their minimum wage and overtime poster, which should be posted in a location that is easily ...