What you'll learn
- A Higher Threshold Than Most Comparable States
- The 'Fixed Pay Range' Requirement — No Open-Ended Ranges
- Disclosure of Other Compensation Eligibility
- Penalties and Enforcement
- Building Minnesota Into a Multi-State Compliance Process
Minnesota's pay transparency requirement, effective January 1, 2025, applies a notably higher 30-employee threshold than most comparable states, meaning a real share of Minnesota's employer base falls outside the requirement entirely — but for those it does cover, the law's 'fixed pay range' language is more specific than most, directly foreclosing the open-ended salary ranges some employers rely on elsewhere. This guide covers exactly what the fixed-range requirement demands, why a range that's fully compliant in another state may still fall short here, the separate disclosure requirement for bonus and commission eligibility, and how Minnesota's own outright non-compete ban adds a second, distinct compliance obligation on top of the pay transparency requirement.
A Higher Threshold Than Most Comparable States
Quick answer
Minnesota's pay transparency requirement, added to the state's existing Equal Pay for Equal Work Act and effective January 1, 2025, applies to employers with 30 or more employees — a notably higher threshold than California's or Washington's 15-employee standard, New York's or NYC's 4-employee standard, or the no-minimum standards in Colorado and Maryland. This means a genuinely large share of Minnesota's small and mid-size employer base falls entirely outside the posting requirement, which is a real contrast to most of the other states covered in this series.
Employers operating across multiple states need to track this threshold difference carefully — a company with 20 Minnesota-based employees might be fully exempt from Minnesota's own posting requirement while still being covered under Colorado's or Maryland's no-minimum standard for any employees based in those states, meaning a single national compliance template can't simply apply the most permissive state's standard everywhere and assume it's automatically compliant in every state.
At least one Minnesota-based employee is also required for coverage, following the standard multi-state pattern — a national employer needs to separately verify it has crossed the 30-employee company-wide threshold and has at least one genuinely Minnesota-based employee before Minnesota's posting requirement applies to any of its listings.
The 'Fixed Pay Range' Requirement — No Open-Ended Ranges
Quick answer
Minnesota's law specifically requires disclosure of a 'fixed pay range,' defined as a range with both a minimum and maximum rate of pay that the employer reasonably expects to pay for the position at the time of posting. This language is more specific than some other states' more general 'good faith range' standard, and it directly forecloses a common workaround seen in job postings elsewhere: an open-ended range like 'starting at $60,000' or '$80,000+' with no stated ceiling.
Employers who have relied on unbounded ranges in postings for other states — either out of habit or as a way to avoid committing to a maximum figure — need to specifically revise their posting language for Minnesota-covered roles to include both a floor and a genuine ceiling. This is a structural compliance gap that a general 'we already disclose salary ranges' assumption can miss entirely if the existing range language was never actually bounded on both ends.
The fixed pay range needs to reflect the employer's genuine expectation at the time of posting, consistent with the good-faith standard applied across virtually every comparable state law — a technically bounded range that's implausibly wide, spanning multiple job levels or an unreasonably large dollar spread, invites the same kind of enforcement scrutiny seen elsewhere, even though it technically satisfies the fixed-range requirement's literal structure.
Minnesota's law, effective January 1, 2025, applies to employers with 30 or more employees — a notably higher threshold than most comparable states, which means many small and mid-size Minnesota employers remain outside the posting requirement entirely, unlike in Colorado or Maryland where no such size exemption exists.
Disclosure of Other Compensation Eligibility
Quick answer
Beyond the fixed pay range itself, Minnesota's law requires the posting to include a general description of all the benefits and other compensation, including but not limited to significant perks such as health insurance, retirement benefits, and eligibility for bonuses, commissions, or profit-sharing that the employer reasonably expects to offer for the position. This benefits-inclusive standard aligns Minnesota with Washington's, Illinois's, and New Jersey's more comprehensive disclosure requirements rather than New York's narrower salary-only standard.
The specific mention of eligibility for bonuses, commissions, and profit-sharing is worth calling out separately from a generic benefits description, since these variable compensation components are frequently a substantial part of total pay for sales and certain other commercial roles — omitting a clear statement of eligibility for these components, even while including a compliant base salary range, risks understating the disclosure requirement's actual scope for roles where variable pay is a significant part of total compensation.
Employers building role-specific compensation disclosure templates, as recommended for Washington's similar requirement, should extend the same practice to Minnesota — a single generic benefits blurb applied uniformly across a commission-eligible sales role and a fixed-salary operations role will likely under-disclose for one of them regardless of which one the template was originally designed around.
Penalties and Enforcement
Quick answer
The Minnesota Department of Labor and Industry enforces the law, with civil penalties for violations following the general pattern seen across comparable state laws — escalating penalty exposure for continued or repeat noncompliance rather than a single flat fine regardless of pattern or duration. Employers should confirm current specific penalty figures directly with the Department of Labor and Industry given the law's relatively recent effective date and the likelihood of continued interpretive guidance.
Given Minnesota's higher 30-employee threshold, a smaller share of complaints is likely to originate from very small employers relative to states like Colorado or Maryland — but mid-size and large Minnesota employers, and any national employer with Minnesota-based operations crossing the 30-employee mark, should treat the threshold determination as an active, ongoing compliance check rather than an assumption made once and never revisited as headcount changes over time.
Related reading
Building Minnesota Into a Multi-State Compliance Process
Quick answer
Audit existing job posting templates specifically for open-ended salary ranges before extending them to Minnesota-covered postings — a range structure that's been perfectly compliant in a state without a 'fixed range' requirement may need direct revision to add a genuine ceiling before it satisfies Minnesota's more specific standard.
Build a bonus, commission, and profit-sharing eligibility disclosure into your standard benefits description template for any role where variable compensation is a meaningful part of total pay, rather than relying on a base-salary-only disclosure that technically satisfies a narrower state's requirement but falls short of Minnesota's more specific standard.
For how Minnesota's higher threshold and fixed-range requirement compare to the broader landscape, see our guide on Maryland's wage range transparency law and our overview of pay transparency laws across the US — and pair Minnesota compliance with a broader look at state non-compete restrictions, since Minnesota is also one of the small number of states with its own outright non-compete ban, making it a state where multiple distinct compliance obligations layer on top of each other for the same hiring process.
Minnesota specifically requires a 'fixed pay range' rather than an open-ended range with no ceiling, and separately requires disclosure of whether the position is eligible for other forms of compensation like commissions, bonuses, or profit-sharing — a structural requirement that catches employers who post a range with an unbounded top end, such as 'starting at $60,000.'
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InCruiter Editorial Team
AI Hiring Research · Interview Intelligence · Enterprise Talent Strategy
The InCruiter editorial team covers AI-driven hiring, interview intelligence, and modern talent acquisition strategy. Our guides draw on platform data from 2,000+ hiring teams, conversations with talent leaders, and published research in industrial-organizational psychology.
