by David Washburn, BGAV Treasurer

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If you’re involved in hiring or managing staff at your church, there’s a new state law you need to know about. Virginia’s Pay Transparency law took effect July 1, 2026, and it changes some of the basic ground rules around how churches post jobs, talk about pay, and handle salary conversations with staff and applicants.

The good news: this isn’t as complicated as it sounds, and much of it reflects practices many churches already follow. Here’s what you need to know, in plain terms.

Who This Applies To

The law does not apply to your ministerial staff—pastors, associate pastors, and other roles that meet the federal criteria for exempt ministerial functions. That exemption stays intact.

But it does apply to everyone else: your administrative staff, office personnel, maintenance and hospitality workers, hourly employees, and any other nonexempt positions. If your church employs a receptionist, a bookkeeper, a facilities coordinator, or part-time hourly help, this law covers how you hire and pay them.

My suggestion is to sort your positions into two buckets—ministerial and everything else—and apply this guidance to the “everything else” bucket.

Three Things to Change Right Now

1. Stop asking about salary history.

When you’re hiring for a nonexempt position, you can no longer ask candidates what they currently make or have made in the past. This includes applications, in interviews, or through informal conversation. If a candidate offers that information on their own without being asked, you’re allowed to hear it and even use it to offer them more, but you can never use it as a reason to offer less.

The simplest fix: train whoever does your hiring interviews to leave out salary history questions, and to base offers on the role and your budget, not on what someone made elsewhere.

2. Include a pay range in every job posting.

Any time you post an opening for a nonexempt position—whether it’s an external ad or an internal posting for a promotion or transfer—you now need to include the wage or a pay range. This applies to hourly and salaried nonexempt roles alike.

You don’t need to nail down an exact figure. The law allows a “good faith estimate,” meaning a reasonable range based on your budget, what similar roles pay, or your own past pay scales for that position. If a current employee asks what the pay range is for their own job, you’re required to share that too.

3. Be ready to correct mistakes quickly.

If you post a job without a pay range, you’re not automatically in legal trouble. The law gives employers 15 business days to fix the posting after receiving written notice of the oversight, and doing so protects you from a private lawsuit over that specific mistake. It’s a grace period, but it only helps you if you act on it promptly, so if someone flags a missing pay range, don’t let it sit.

What Not to Do

Don’t punish, discipline, or pass over anyone—staff or applicant—for exercising their rights under this law. That includes someone who declines to share their salary history or who asks what the pay range is for a position. Retaliation of any kind opens your church up to real financial exposure: the Attorney General can issue civil penalties up to $1,000 for a first violation and up to $5,000 for repeat violations.

A Practical Next Step

If your church has a personnel committee, search committee, or HR-related team, this is worth a short conversation at your next meeting. Walk through your current job postings and hiring practices together, and ask two simple questions: Do our nonexempt postings include a pay range? Have we trained the people leading our interviews to avoid salary history questions?

Most churches will find they’re already close to compliant or that getting there just takes a small adjustment to a template or a talking point in the interview process. This law isn’t asking churches to overhaul how they operate; it’s asking for a bit more openness with the people who serve alongside us on staff. That’s a spirit most congregations will recognize as consistent with how we’re already called to treat one another.

This article is intended as general guidance for church leaders and is not a substitute for legal counsel. Churches with specific questions about their staffing structure should consult an attorney familiar with Virginia employment law.

Rev. David Washburn is BGAV’s treasurer.

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