Colorado Asserts Nationwide Reach Over Most On-Line Job Postings of “Colorado Employers” in New Guidance Re Pay Transparency Rules

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On Friday, December 18th, the Colorado Division of Labor Standards & Statistics (“DLSS”) issued Interpretive Notice & Formal Opinion #9 (“INFO #9”) regarding the pay transparency requirements in the new Colorado Equal Pay for Equal Work Act (“EPEWA”).

Most of the guidance is helpful to comply with the EPEWA, addresses technical details of covered job postings, and discusses which jobs must have the EPT (“Equal Pay Transparency”) data Colorado now requires of most job postings.  As to the extra-territorial reach issue which has been vexing employers, the DLSS boils it down to four simple rules (two

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