Virginia's pay transparency clock started July 1. Your job postings are already exposed.
Virginia's pay transparency law took effect July 1, 2026. Every job posting and internal transfer announcement without a documented good-faith range is already a live compliance exposure.
The law is not coming. It arrived. Virginia's pay transparency statute took effect July 1, 2026, and it applies to any employer with one or more employees in the state. According to Catapult, every new public job posting and every internal transfer announcement must include a good-faith wage or salary range. That requirement covers your external careers page, the Slack message your HR lead posts when a senior role opens internally, the offer letter process, and any posting a third-party recruiter runs on your behalf.
The penalty structure is what makes this urgent. Catapult reports first violations run up to $1,000, and each subsequent violation reaches up to $5,000. Workers can sue within one year. If you posted ten roles since July 1 without ranges, you are not looking at one exposure; you are looking at ten, and the plaintiffs' bar in Virginia is already watching the first wave of filings.
The comp question your managers are answering at 11 PM without documentation is now also a legal question, and the clock on it started months ago.
What "good-faith range" actually requires
A range is not a number you invent the morning the job goes live. It has to reflect what you would actually pay someone in that role, given your current salary bands and budget. If your bands are not documented, the range you post is not defensible. Virginia's law also prohibits asking applicants about salary history or using it in the offer process, per Catapult, which means your intake forms and recruiter scripts need the same audit as your postings.
The practical gap at most small and midsize companies is infrastructure, not intent. You have no written bands, so every range is a guess, and a guess is not a good-faith range under the statute. Documented salary bands are the foundation the law assumes you already have; without them, any range you post is a liability rather than a defense.
Where the exposure is hiding
Most founders think about external postings. The internal transfer announcement is where the exposure actually concentrates. When a manager sends a message about a new role on the team without a range, that is a violation. When your recruiter posts on LinkedIn without a range, that is a violation traceable to you. Skillenai's analysis of 118,706 US job postings found that compliance rates vary enormously by state, driven almost entirely by whether a law is in force, not by employer intent.
Audit every posting channel this week: your ATS, LinkedIn, Indeed, any internal job board, and any email or Slack announcement about open roles. Pull the last 90 days. For every posting without a documented range, assess whether it is still live and correct it. For postings already closed, document the range retroactively using your current band data. Build that documentation before the next hire, not after the first demand letter arrives. The audit itself is the action; run it now, record what you find, and close every gap before you post the next role.