Salary Ranges in Job Ads: Where the Law Requires Them in 2026, Country by Country

Most articles on this topic are written for HR teams worried about fines. This one is written for the person reading the ad.

Pay in a job ad changes how you job hunt. You can skip roles that will never pay what you need before you spend an evening on the application. You walk into the interview knowing the number the employer has already admitted to. And in many of these places, the same laws stop the employer asking what you earn now, which has quietly set the starting point of salary talks for decades.

We read the primary texts where we could: the directive in the EU Official Journal, the GOV.UK consultation, and the state and provincial guidance. Where a country's status comes from a law firm tracker instead, the table says which one and when it was updated. Every date was checked on 21 October 2026.

The short answer, as of 21 October 2026

• European Union: a 2023 directive gives every job applicant the right to be told the starting pay or its range in time to negotiate, for example in the advert or before the interview, and bans questions about pay history. The deadline to make it national law was 7 June 2026. Italy, Poland's recruitment rules, Malta, Lithuania and Slovakia are in force, Greece starts on 1 November, and most other member states are still drafting.
• United States: 14 states and Washington DC require pay in the posting itself. Virginia, Maine and Connecticut joined this year, and Delaware follows in September 2027.
• Canada: British Columbia, Prince Edward Island and Ontario require pay in public job postings. Ontario also caps the range at $50,000 and makes employers say whether AI screens applicants.
• United Kingdom: no law yet. A government consultation proposing pay in every job advert closes at 5pm on 27 October 2026.
• Everywhere else we looked, including Australia, India and the Gulf states, showing pay is still the employer's choice.

What the EU directive actually says

The law behind all of this in Europe is Directive (EU) 2023/970, adopted on 10 May 2023. Article 5 is the part that matters to job seekers, and it is short enough to quote. It starts:

“Applicants for employment shall have the right to receive, from the prospective employer, information about: (a) the initial pay or its range”

That pay has to rest on objective criteria that are neutral as to gender, and where a collective agreement applies to the job, you are entitled to its relevant terms too. The article then says how you get it: “in a manner such as to ensure an informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise.” Then comes the line that changes the salary conversation: “An employer shall not ask applicants about their pay history during their current or previous employment relationships.” Job titles and vacancy notices must also be gender neutral.

Two more articles reach you once you are hired. Article 6 makes employers share the criteria they use to set pay and pay progression. Article 7 lets workers ask for their own pay level and the average pay, broken down by sex, of people doing the same work or work of equal value, and the employer must answer within two months. Article 34 set the deadline for all of this to become national law: 7 June 2026.

Which EU countries have written it into law

A directive only binds employers once a country turns it into national law, and on 7 June 2026 most of the 27 had not. This is where each one stood on 21 October 2026. The status for most countries comes from two law firm trackers, Ius Laboris and Pinsent Masons, which are second hand sources. The source column says which one and when it was last updated, so you can judge how fresh each line is.

If you are applying in a country that has not finished its law, nothing stops you asking for the range, and many employers already give it. The law just cannot force them yet.

The United States: 14 states and Washington DC

There is no federal rule in the US. Instead, a growing list of states requires the pay range in the posting itself. These are the ones in force on 21 October 2026, linked to each state's own guidance or statute.

Coming next: Delaware signed its law on 26 September 2025 and it takes effect on 26 September 2027, for employers with 26 or more employees. Nevada and Rhode Island take a softer line: the range has to be given after an interview or on request, not in the ad. Some cities moved before their states, New York City among them, on 1 November 2022.

Canada: three provinces, three rulebooks

Ontario's rules go further than pay. Since 1 January 2026, an applicant who is interviewed must be told whether a hiring decision has been made within 45 days of the interview, or of the last interview if there were several. If you have ever waited months for an answer that never came, that line is for you.

British Columbia shows what the rules do in practice. On 1 June 2026 the provincial government reported that, as of March 2026, 81% of job postings on Indeed in B.C. included pay information, against 56% across Canada.

The United Kingdom: a consultation, not a law

There is no legal duty to show pay in a UK job advert today. That may change. On 14 July 2026 the Office for Equality and Opportunity published Equal pay and pay discrimination, a consultation covering England, Scotland and Wales. Its proposal is plain:

“we propose introducing a requirement for all employers to publish pay information in job adverts”, and “In the absence of a job advert, the employer must give the candidate this information in writing before the job interview.”

It asks whether that should be a range, a specific salary or a benchmark rate, and what else belongs alongside it, such as collective agreement terms or other financial benefits. It also says the government “will seek an extended implementation period before any measures are commenced”, so even a yes would not change adverts overnight. The document notes that most employers already publish pay ranges voluntarily. Responses close at 5pm on 27 October 2026, and anyone can respond, job seekers included.

How to read a salary range

A range in an ad is not a promise of the top figure. Here is what the laws say it is, and how to use it.

• It is a good faith estimate. California calls the pay scale a good faith estimate of what the employer reasonably expects to pay, and New York and Massachusetts use the same idea. A range the employer never intended to pay breaks the law in those states.
• You can land outside it. Vermont's law says nothing in it stops an employer hiring for more or less than the advertised range, and Colorado allows the same where the posted range was an honest estimate. Strong candidates do get offers above the top.
• Open ended ranges do not count. New York rejects wording like $17 an hour and up, British Columbia rejects up to $30 per hour and competitive wage, and Colorado rejects $30,000 and up. If you see one of those where a law applies, the ad does not comply.
• Wide ranges are mostly legal. British Columbia sets no cap for now, and Virginia's governor acknowledged when its law took effect that a broad range could still comply. Ontario is the exception with its $50,000 limit.
• Benefits are part of the deal. Colorado, Washington, Illinois, Minnesota, New Jersey, Maryland and Connecticut also require a general description of benefits, so compare whole packages, not just salaries.

When the ad does not show the pay

Ask, and ask before the interview rather than after the offer. One sentence to the recruiter is enough:

In EU countries that have passed the directive, the employer has to give you the starting pay or range in time for an informed negotiation anyway, so you are only asking for what the law already gives you. In the UK, the government itself says most employers already publish ranges, so the question is ordinary. In India, recruiters expect to talk numbers on the first call, and our guide to the Indian resume format covers how CTC and notice period fit in. If an employer will not give any figure at all before an interview, that tells you something too.

The pay history question is banned in more places than you think

The question “what do you earn now?” does more damage than a hidden range, because it ties your next salary to your last one. It is now banned under the EU directive wherever that is in force, including Poland and Italy, and in many US states, among them California, New York, Massachusetts and, since July 2026, Virginia. British Columbia and Prince Edward Island ban it in Canada.

If you are asked anyway, you do not have to answer. A calm reply keeps the conversation on the role:

In the UK and India the question is still legal, and in India it is routine. You can still steer it the same way, by answering with what you expect rather than what you earn.

What we could not verify

Law moves faster than trackers. Some EU statuses above come from a tracker last updated in July, and countries like Romania, Finland and Sweden may have moved since. The trackers also disagree on a few countries, Austria and Belgium among them, and we have said so rather than pick one. Several US laws have exceptions for small employers, internal promotions or jobs done entirely outside the state that we have not listed. And this is a guide for job seekers, not legal advice: if you are an employer, read the national law or ask a lawyer.

Sources

• Directive (EU) 2023/970, Official Journal of the European Union, L 132, 17 May 2023: Articles 5, 6, 7 and 34 quoted above.
• Ius Laboris transposition tracker, updated 30 September 2026, and Pinsent Masons member state guide, updated 9 July 2026. Second hand.
• Legal 500 on Italy's Legislative Decree 96/2026, IBA on Poland's recruitment rules, Malta Legal Notice 173 of 2026, Dansk Industri on Denmark's bill, 8 October 2026.
• GOV.UK, Equal pay and pay discrimination, published 14 July 2026, closing 27 October 2026.
• Government of Ontario, requirements for publicly advertised job postings; Province of British Columbia, wage or salary information on job postings, updated 24 February 2026; B.C. news release, 1 June 2026; Stewart McKelvey on Prince Edward Island.
• US state guidance and statutes, linked from each row of the US table.

Frequently asked questions