This chapter presents an overview of companies’ requirements to report gender-disaggregated pay data in 21 OECD countries. Most countries require detailed, gender-disaggregated pay information across different categories like job classification or level of seniority. To address intersecting disadvantage, a few countries require gender pay gap statistics be further disaggregated by race/ethnicity. This chapter also takes stock of novel non-pay gender-disaggregated data reporting requirements, which exist in at least 24 OECD countries. These requirements most commonly include reporting gender gaps in employee headcounts and the share of top positions held by women.
Reporting Gender Pay Gaps in OECD Countries
3. The nature of pay gap reporting: What is reported?
Abstract
Key findings
Out of the 21 OECD countries with pay reporting measures in the private sector, eight require employers to report gender gaps in mean or median pay (difference between men and women’s pay), while another eight require employers to report mean/median pay by gender (separately for men and women). The remaining countries either do not specify what statistical information must be provided, or they require the reporting of individual salaries for all employees. Only two countries – Korea and the United Kingdom – require simply a top-line, company-wide gender pay statistics.
Countries have different guidelines on what should be counted as pay. Pay reporting requirements can include variable components, such as bonus pay within the standard calculation, or can require variable components be reported separately.
Most countries require that gender pay information be further disaggregated by job category (16 out of 21 countries). Gendered pay information is also commonly reported by level of seniority, education and/or qualification achieved, and, slightly less often, by age. Most OECD countries with pay reporting measures do not require pay information to be further disaggregated by race/ethnicity.
At least 24 countries require private sector employers to provide non-pay statistics by gender. This often entails reporting the gender distribution of workers in a given firm and the gender composition of top positions, such as the share of managers or corporate board members who are women.
Policy takeaway: While presenting the overall gender wage gap at the firm level is useful, governments should consider requiring firms to assess disaggregated results by subgroups. Mindful that calculating too many subgroup statistics may risk administrative burden, a practical solution is to start by requiring gender-disaggregated mean or median pay by job category, to enable simple comparisons of ostensibly comparable workers. Good practice would include gender-disaggregated pay statistics for additional subgroups such as level of seniority, parent status, education, and racial/ethnic background.
3.1. Required content in pay gap reporting
Pay reporting regimes require, at the minimum, average or median pay statistics disaggregated by gender. Table 3.1 provides an overview of what pay information is required in the private sector as part of mandatory pay reporting and whether this information is further disaggregated by worker characteristics. For instance, many countries require gender pay gaps or pay information to be further disaggregated by job category, while very few countries – notably Canada and New Zealand (public sector1) – require gender pay gap statistics also be disaggregated by race/ethnicity.
Presenting the overall, firm-level gender pay gap has benefits. It helps to reduce administrative burden on firms, as firms do not need to assess disaggregated information; it encourages businesses to consider how horizontal and vertical segregation contributes to wage discrepancies; and it helps to increase awareness of pay equity with a single, tangible statistic (OECD, 2021[1]). This strategy is used in the United Kingdom and Korea (see Box 3.1).
At the same time, reporting only the total gender pay gap can hide disparities and perhaps even discrimination among employees in comparable positions. This lack of clarity can make equal pay disputes even more difficult to resolve. In other words, reporting only the company-wide gender pay gap might not go far enough to support specific individuals who could be unfairly underpaid for doing equal work or work of equal value (OECD, 2021[1]).
Box 3.1. Country highlights: United Kingdom and Korea lean into public pressure to promote gender equality
United Kingdom
The United Kingdom implemented its company pay reporting requirements in 2017 as part of the Equality Act 20101(Gender Pay Gap Information) Regulations. The aim of the reporting requirements is to increase transparency around gender pay disparities and encourage employers to take action to address them.
Relevant employers are required to assess the pay information across their organisation to publish the mean and median gender gap in pay and bonuses. These statistics must be visible on their organisation’s website and on a UK Government website dedicated to pay gap reporting (https://gender-pay-gap.service.gov.uk/).
Both private and public sector employers with 250 or more employees are subject to the regulations. The reporting process must be completed annually by 30 March for the public sector and by 4 April for the private for-profit and non-profit sectors. Employers are provided with a digital service for reporting data and a website with guidance (see Chapter 7 for more).
Although there are no direct penalties for non-compliance, the UK’s Equality and Human Rights Commission can take legal action against employers who refuse to report, which can result in unlimited fines. Beyond financial penalties, public pressure and reputational risk have provided strong incentives for employers to report, as well; the government credits this with facilitating 100% compliance by firms in the first two years of reporting.
Academic research in the United Kingdom have found that gender pay gap reporting requirements have led to a slight reduction in the gender pay gap (Jones and Kaya, 2022[2]; Jones, Kaya and Papps, 2022[3]; Blundell, 2021[4]; Duchini, Simion and Turrell, 2020[5]). However, this reduction seems to be largely due to a decrease in male wages rather than an increase in female wages (Blundell, 2021[4]; Duchini, Simion and Turrell, 2020[5]). Findings further suggest that regulations have influenced hiring practices, with affected employers offering more attractive policies to women (Duchini, Simion and Turrell, 2020[5]). During the COVID‑19 pandemic, when the pay gap reporting system froze, organisations that reported their gender pay gap showed a 6% lower gap a year later compared to those that did not report (Jones, Kaya and Papps, 2022[3]). This has been attributed to an increase in the proportion of women in the top pay quartile and a rise in the concentration of women in the overall workforce (Jones and Kaya, 2022[2]). For a longer discussion of academic evidence on pay reporting, see Chapter 1.
Korea
Korea’s Pay Transparency Measure requires all public sector employers, and private sector employers with 500 or more employees (or 300 or more for enterprise groups subject to disclosure), to report their yearly gender pay gaps – including basic salary, bonuses and allowance paid – as well as the number of employees by job category and seniority.
Employers must submit reports through a website which the government monitors. On the website, employers have access to various resources, such as a direct contact number for government personnel, a chatbot-enabled platform, booklets, and videos on how to report. For more information, refer to Chapter 7.
Some businesses are listed publicly in the Official Gazette or on the Ministry of Employment and Labour website for six months if their gender pay gap results fall into the following categories:
Businesses whose ratio of employed female workers or managers by job categories is less than 70% of the average by industry and size, three times in a row, prior to the date of disclosure of the list, and
Business owners who failed to comply with the request to implement appropriate measures after submitting their performance results.
The publicised information includes the businesses’ names, addresses, number of employees (by gender), number of managers (by gender), and employment standards of female employees.
Businesses with figures below 70% of the average for each sector are also required to establish an improvement plan with implementation guidance provided.
1. The Equality Act 2010 came into force on 1 October 2010. It replaced previous anti-discrimination laws with a single Act, making the law easier to understand and strengthening protection in some situations. The Act provides a legal framework to protect the rights of individuals and advance equality of opportunity for all. For more information, refer to https://www.legislation.gov.uk/ukpga/2010/15/contents or https://www.equalityhumanrights.com/en/equality-act-2010/what-equality-act.
Source: OECD GPTQ (2022), unless otherwise cited.
Table 3.1 presents the information required in pay gap reporting, identifies whether countries have implemented non-pay reporting requirements (elaborated further in Table 3.3) and states whether follow-up mechanisms are embedded in pay reporting. Table 3.2 and the related discussion in Section 3.2.1 elaborate on the details of different job categorisations/job classification systems used across the OECD.
Table 3.1. Required content in pay reporting
Summary of OECD countries’ pay reporting requirements in countries with mandatory reporting in the private sector, 2022.
Country |
Pay information to be reported |
(Y/N) Pay information further disaggregated by: |
Non-pay reporting requirements (Table 3.5) (Y/N) |
Follow-up mechanism (Y/N) |
|||||
---|---|---|---|---|---|---|---|---|---|
Job category |
Seniority |
Education |
Ethnicity |
Age |
Other |
||||
Austria |
By gender: mean or median wages. |
Y |
N |
N |
N |
N |
By remuneration or salary group scheme. |
Y |
N |
Australia |
For all employees: the annualised, full-time equivalent salaries, both (1) base salary (earnings before tax, including salary sacrificed items and excluding superannuation and other payments/benefits) (2) total remuneration (base salary plus all bonuses, allowances, superannuation, and other payments). From 2024, employers will be reporting on actual earnings, including base salary and total remuneration (including bonuses) of their employees. |
Y |
Y |
N |
N |
N |
By employment status and type, and graduate or apprentice status. Age and primary work location can be reported on a voluntary basis but will be mandatory from 2024. |
Y |
Y |
Belgium |
By gender: wages, benefits, employer’s contributions for extra-legal insurance, and other extra-legal benefits. |
Y |
Y |
N |
Y |
N |
N |
Y, but part of a different measure |
If there is a gender gap within the company, an action plan can be put in place (not mandatory). |
Canada1 |
EEA: Gender gap in mean and median hourly pay, bonus pay, and overtime pay. Note that only gaps are reported, not mean or median remuneration by gender. PEA: Compensation (including salaries, vacation pay, bonuses, and contributions to pension funds) of predominantly female job classes are compared to that of predominantly male classes. |
Y |
N |
N |
EEA: Y, Aboriginal and non-Aboriginal people PEA: N |
N |
EEA: By industrial sector, region, and disability and (visible) minority status. PEA: N |
EEA: Y PEA: N |
Y |
Chile |
Gender gap in mean gross basic salary (reported as a ratio; the salary of female executives and workers over that of male executives and workers) |
Y |
N |
N |
N |
N |
By level of responsibility. |
Y |
N |
Denmark |
By gender: mean pay (including basic salary and other cash or in-kind benefits). |
Y |
N |
N |
N |
N |
N |
Y, but part of a different measure |
N |
Finland2 |
Finland requires showing that mean salaries (including basic salary and variable component such as bonuses) are equal. These mean values can be expressed either in euros or as women’s mean wages as a percentage of men’s mean wages. |
N |
N |
N |
N |
N |
It is not specified how pay information should be disaggregated. Only that it needs to be disaggregated. Important factors when comparing jobs are quality and content of work tasks, competence, responsibility, workload and working conditions. |
N |
Y |
France |
Gender gap in mean pay, including ordinary basic or minimum wage or salary and all other benefits and accessories paid (results in a score out of 40 points). Four other non-pay indicators collectively result in a score out of 60 points. |
Y |
N |
N |
N |
Y |
N |
Y |
Y |
Iceland |
By gender: mean fixed salary, fixed additional payments and all extra payments. |
Y |
N |
N |
N |
N |
N |
N |
Y |
Ireland |
Gender gaps in mean and median hourly wage pay. Data on bonus pay reported separately. |
N |
N |
N |
N |
N |
By part-time and temporary contract status. |
Y |
Y |
Israel |
Gender gap in mean pay, as percentage. Employers must also provide employees information about the pay level they belong according to job type or ranking, and the gender pay gap in that group. |
Y |
Y |
N |
N |
N |
By salary class and hours worked. |
Y |
Y |
Italy |
By gender: annual gross overall remuneration (basic salary plus any additional amounts paid to the employee) at the beginning and at the end of the reporting period. Additional amounts are also reported separately. |
Y |
N |
N |
N |
N |
By occupation |
Y |
N |
Japan |
Gender gap presented as the proportion of female workers’ annual salary (including benefits, allowances, and bonuses) relative to that of male workers. Severance pay and commuting allowance can be excluded at the discretion of each employer. |
N |
N |
N |
N |
N |
By regular workers v. non-regular worker status. |
Y |
Y |
Korea |
Aggregate gender gap in yearly mean pay (including basic salary, bonuses and allowance paid) |
N |
N |
N |
N |
N |
N |
Y |
Y |
Lithuania |
By gender: mean pay (including bonuses). |
Y |
Y |
Y |
N |
N |
By type of employee, job position, and salary class. |
Y |
N |
Norway |
By gender: ordinary remuneration (including various supplements, e.g. hourly wages, piecework wages, bonuses, overtime, free telephone/car/newspaper subscription, occupational pensions). It is optional to report the pay gap in kroner or a percentage. |
Y |
N |
Y |
N |
N |
By effort, level of responsibility and working conditions. |
Y |
Y |
Portugal |
For all employees: monthly basic pay (gross pay for normal hours of work), regular and non-regular benefits, and overtime pay, as well as the mechanism of wage bargaining. |
Y |
Y |
Y |
N |
Y |
By region. |
Y |
Y |
Spain |
By gender: mean and median salary (broken down by base compensation, supplements, and non-wage payments). |
Y |
N |
N |
N |
N |
N |
Y |
Y |
Sweden |
Not specified which statistics need to be reported. The employer is to annually survey 1. provisions and practices regarding pay and other terms of employment that are used by the employer, 2. pay differences between women and men performing work that is to be regarded as equal or of equal value. Company car, housing or travel benefits and the like that constitute salary must be included in the employer’s survey. |
N |
N |
N |
N |
N |
Sweden has a particular approach to the assessment of whether existing pay differences are directly or indirectly associated with gender. This is discussed in further detail in Box 3.4 and Chapter 4. |
Y |
Y |
Switzerland |
Beyond pay, it is not specified which variables must be included. The federal government provides a free analysis tool, Logib. Under Logib module 1 (recommended for employers with 50 or more employees), for all employees: monthly/hourly basic pay, allowances, bonuses and other special payments benefits, and overtime pay. |
Y, Under Logib module 1 |
Y, Under Logib module 1 |
Y, Under Logib module 1 |
N |
N |
Logib module 1 disaggregates gender gaps further by education, seniority, potential work experience, level of qualifications and professional position. |
Y, but part of a different measure |
The law does not provide for any follow-up other than repeating the analysis (cf. 20‑21). It is the responsibility of the employees, shareholders of listed companies and the social partners to ensure a follow-up. However, experience shows that companies often voluntarily carry out an initial analysis and make corrections on a regular basis. |
United Kingdom |
Gender gaps in mean and median pay and bonuses. |
N |
N |
N |
N |
N |
N |
N |
N |
Note: Table summarises the content required in company pay reporting requirements in countries with such requirements.
1. Canada’s pay reporting regulation is two‑fold. The Employment Equity Act applies to federally regulated-private sector employers, and the Pay Equity Act applies to federally regulated employers in both the private and public sectors.
2. For more information on Finland’s measures refer to the box on “The Nordic approach” (Chapter 4) and https://julkaisut.valtioneuvosto.fi/bitstream/handle/10024/75131/Act_on%20Equality_between_women_and_men_2015_FINAL.pdf?sequence=1
Please refer to Table 2.1 for information on which employers are subject to reporting rules, to Section 3.2 for a discussion of job classification systems used when disaggregating pay information by job category, to Chapter 4 for further information about follow-up mechanisms in equal pay audits, and to Table 3.3 for information on the content required in non-pay reporting.
Source: OECD Gender Pay Transparency Questionnaire (GPTQ) 2022 (see Annex A)
3.1.1. Most pay reporting measures require employers to report gender gaps in mean/median pay
In most countries, gender pay differences are reported (at a minimum) as mean or median gender pay gaps across the company. This includes Canada, Chile, France, Iceland, Ireland, Israel, Japan, Korea, New Zealand (public sector, see endnote 1), and the United Kingdom.
The definition of pay varies by country, with some countries including bonuses and other variable components on top of base pay. These countries include Canada (under the Pay Equity Act2), France Iceland, Japan, and Korea. In other countries, bonus and variable pay gaps are reported separately, for instance in Canada (under the Employment Equity Act, see endnote 2), Ireland, and the United Kingdom. This approach of separating base and bonus pay is similar to that in the EU Directive on pay transparency (Chapter 2, Box 2.2).
Another common approach is to have employers report mean or median pay by gender – that is, separately for women and for men. In countries with gender-disaggregated pay reporting, this can either include variable components like bonuses (Denmark, Lithuania, and Norway) or can report on these variable components separately (Belgium, Italy, and Spain).
Finland and Sweden do not specify the exact statistics to be reported in their legislation. However, Finnish rules require that employers show that “salaries (including basic salary and variable component such as bonuses) are equal” between men and women and Swedish rules mandate companies to analyse pay differences between women and men as well as provisions and practices relating to pay. Reporting requirements in both countries are embedded within equal pay audits (see Chapter 4), which demand a thorough and comprehensive understanding of potential gender differences among the organisation’s employees.
3.1.2. Some countries offer instructions for calculating gender pay gaps, and many provide software
Many countries have developed practical tools to help employers calculate and report gender pay gaps, such as gender pay gap calculators, online reporting portals, step-by-step guides, checklists, as well as video recordings. Many countries have also designated a first contact point for when questions arise. A more detailed discussion of guidance offered to employers, as well as practical tools for calculating and presenting gender gaps, are presented in Chapter 7 of this report.
Instructions for how to collect and analyse gender wage gap data can be basic or very detailed. In Japan, for example, employers are simply instructed to divide the female workers’ annual salary by that of male workers. The Irish regulations (Employment Equality Act, 2022, p. 7[6]) provide a good example for detailed instructions on computing gender pay gaps. For instance, the following data relating to mean hourly remuneration should be published in Ireland:
Art. 7(1) (…)
(a) the difference between the mean hourly remuneration of relevant employees of the male gender and that of relevant employees of the female gender expressed as a percentage of the mean hourly remuneration of relevant employees of the male gender;
(b) the difference between the mean hourly remuneration of part-time employees of the male gender and that of part-time employees of the female gender expressed as a percentage of the mean hourly remuneration of part-time employees of the male gender;
(c) the difference between the mean hourly remuneration of relevant employees of the male gender on temporary contracts and that of relevant employees of the female gender on such contracts expressed as a percentage of the mean hourly remuneration of relevant employees of the male gender on temporary contracts.
Art. 7(2) For the purposes of subparagraphs (a), (b) and (c) of paragraph (1), the difference between the mean hourly remuneration of persons of the male gender and that of persons of the female gender, expressed as a percentage of the mean hourly remuneration of persons of the male gender, shall be determined in accordance with the following formula:
[(A – B) / A] x 100, where
(a) in relation to paragraph (1)(a), A is the mean hourly remuneration of all relevant employees of the male gender, and B is the mean hourly remuneration of all relevant employees of the female gender,
(b) in relation to paragraph (1)(b), A is the mean hourly remuneration of all part-time employees of the male gender, and B is the mean hourly remuneration of all part-time employees of the female gender, and
(c) in relation to paragraph (1)(c), A is the mean hourly remuneration of all relevant employees of the male gender on temporary contracts, and B is the mean hourly remuneration of all relevant employees of the female gender on such contracts.
How gender pay gaps are reported to stakeholders matters, too. Using a randomised control trial, the Behavioural Insights Team commissioned by the UK Government Equalities Office tested five alternative ways3 of communicating the wage gap (United Kingdom Government Equalities Office, 2018[7]). The study revealed that benchmarking information – placing a company’s result in the context of other companies’ results – helps readers differentiate between companies with high gender wage gaps and companies with low ones. When statistics are presented in terms of money, rather than a simple percentage, the ability to understand the gender pay gap is maximised. A likely explanation for this is that people relate to monetary comparisons (e.g. 90 pence to every pound) more easily than percentages. The findings of this study have direct implications for the effectiveness of pay reporting rules.
3.1.3. A few countries require reporting salary information for all employees
In a few countries, pay information must be reported for all employees – either as a part of pay transparency regulations, or as part of pre‑existing data collection efforts. For example, the Australian Workplace Gender Equality Agency analyses average firm-level gender pay gaps for base salary and for total remuneration, i.e. base salary plus all bonuses and other benefits. (Please see Box 3.2 for more information).
A handful of countries use pre‑existing data sources with individual-level pay information for their pay gap reporting processes. In Denmark, Statistics Denmark uses linked employer-employee earnings data for every employee to calculate the wage gap. Lithuania also uses individual-level data from social security contributions. Portugal collects and analyses individual workers’ information through a survey called Quadros de Pessoal, which covers all firms with at least one employee in Portugal. Australia is exploring ways by which data already held by the government can be used for similar purposes. For a detailed discussion of these approaches see Chapter 7.
This approach of integrating reported pay information for all employees into a central system enables the comparison within a company, across companies and the sector more broadly, at regional levels, and across time. This strategy has been recommended by other studies of pay transparency (OECD, 2021[1]) (Cowper-Coles et al., 2021[8]).
Box 3.2. Country highlight: Australia
The Workplace Gender Equality Act 2012 aims to enhance and advance equality for men and women in the workplace, which includes equal pay for both genders. Additionally, the Act aims to assist employers in eliminating obstacles that prevent women from fully and equally participating in the workforce.1
The Act requires non-public sector employers with 100 or more employees to submit an annual report to the Workplace Gender Equality Agency (WGEA) in a confidential manner. WGEA is an Australian Government statutory agency created by the Act. These results must also be shared with individual employees and/or workers’ representatives.
Although some company reporting results are made public, such as the gender distribution of staff and the proportion of full-time and part-time employees, pay gap outcomes are not visible to the public. However, members of the public can search for a company’s pay reporting history and whether they have a formal gender pay equity policy through an online portal.
Australia can therefore identify companies that have not complied with pay gap reporting2 and can impose penalties, such as tabling non-compliance in Parliament and prohibiting non-complying companies from participating in government tenders above a certain threshold. This means that a contract below the threshold does not require compliance with the Act.
1. For more information, refer to https://www.wgea.gov.au/what-we-do.
Source: OECD GPTQ (2022)
3.1.4. Some countries offer less specific guidance on calculating gaps
In some countries, regulation does not specify exactly which statistics need to be reported. For instance, in Switzerland, “beyond pay, it is not specified which variables must be included”. However, the federal government provides an analysis tool called Logib (see Chapter 7 for more information) and recommends its use to employers.
3.2. Pay reporting is commonly disaggregated by job category
Out of the 21 OECD countries that require pay reporting in the private sector, Korea and the United Kingdom are the only ones that ask for only an aggregate, company-level estimate of the wage gap. In all others, more granular information is required to be reported. This is to help identify the different factors that contribute to gender pay gaps within firms and sectors. By examining different characteristics, such as job position, age, education, parenthood status, and even race/ethnicity, countries can understand which women face higher disadvantage and how to best address the barriers they face (OECD, 2021[1]; Cowper-Coles et al., 2021[8]).
Most countries that require gendered pay information to be further disaggregated are interested in gender gaps by job classification (Table 3.1). This is the case in Austria, Australia, Belgium, Canada, Chile, Denmark, Finland, France, Iceland, Italy, Latvia, Lithuania, Norway, Portugal, Spain, and Sweden.
Job classifications are used to group jobs together based on the tasks and duties they involve. This can include ostensibly “objective” criteria that relate to the knowledge and education required, the effort exerted and working conditions, as well as the relevant responsibilities and the difficulty of a role – among other observable characteristics (OECD, 2021[1]). Various job classification schemes are used across OECD countries following national (see those in Table 3.2) or international guidelines, such as the International Standard Classification of Occupations (ISCO) (ILO, 2010[9]).
Some job classification systems in OECD countries are legally required to be gender-neutral or gender-sensitive (see Section 3.2.2). This means that they must aim to classify work based on objective criteria (see above), regardless of the gender of the person doing the job and of the preponderance of one gender in a given job class. These systems should also take into account the historical context and potential biases that may have affected how different jobs have been valued in the past (OECD, 2021[1]).
It should be noted that when gender pay gaps are disaggregated by job position, the pay gap(s) within a firm may appear smaller. This is because men tend to dominate higher-paying positions while women are more likely to be in lower-paying jobs. It is therefore useful to present both the aggregate and subgroup-decomposed gender wage gap estimates, as well as the gender composition of the workforce by job position (see Section 3.5). By doing so, it allows for a more comprehensive understanding of the gender pay gap and its underlying causes. Disaggregating data by job position helps shed light on the disparities within specific occupations and sectors, bringing attention to the issue of occupational segregation.
3.2.1. Gender pay statistics are often disaggregated by standard job classification systems, by job categories used by employers, or in collective agreements
The job categories used for reporting on the gender pay gap vary by country. Most countries recommend using a pre‑defined job classification system. This can be a standard national or international job classification system, a company job classification system, or a classification system used in collective agreements (Table 3.2). The level of detail in these systems affects how comparable different roles are within each classification.
Table 3.2. Job classification systems required or suggested for use in private sector gender pay reporting regulation
Job classification systems required or suggested to be used in countries where gender pay gaps or gendered pay information must be further disaggregated by job categories, 2022.
Country |
Job classification system |
---|---|
Austria |
Company job classification or those used in collective agreements |
Australia |
ANZSCO (Australian and New Zealand Standard Classification of Occupations) at major group level. Employers can voluntarily report to unit level. |
Belgium |
Functional classification of the company or sector; if not, subsidiary function classification (executive, managerial, executive staff). The employer must respect the sectoral job classification in the first place. If a sectoral job classification applies, the job classification at company level should not contain any provisions that conflict with the sectoral collective agreement. |
Canada |
EEA: Employment Equity Occupational Groups (EEOGs), based on the National Occupational Classification, Canada’s national system for describing occupations. PEA: Predominantly female job classes are compared to predominantly male job classes in the same workplace doing work of equal value. Job classes are determined by the employer, or in the case a pay equity committee has been formed, by the committee, and are made up of positions within the workplace that: 1) have similar duties and responsibilities; 2) require similar qualifications; and 3) are part of the same compensation plan and are within the same range of salary rates. |
Chile |
By type of position and function performed |
Denmark |
The 6‑digit DISCO code and/or equivalent classification. DISCO‑08 is the official Danish version of ISCO‑08 with an additional tier that further specialises job functions. |
France |
Categories of equivalent positions. These correspond to the hierarchical level or coefficient (or other method of rating positions) after consultation with the social and economic committee, or to the socio-professional categories (blue‑collar workers; white‑collar workers; technicians and supervisors; engineers and managers). |
Iceland |
Companies can choose their type of classifications as long as the system is not discriminating on the basis of gender. |
Israel |
No response. |
Italy |
Executives, managers, employees, and workers. |
Latvia* |
A gender-neutral job classification, which is determined by the regulations of the Cabinet of Ministers. |
Lithuania |
By occupations/types of economic activity. |
New Zealand* |
Roles specific to organisation or Australian and New Zealand Standard Classification of Occupations (ANZSCO). |
Norway |
More general job categories consisting of same type of work or work of similar value. The assessment and design of the categories should include equal work and work of equal value. |
Portugal |
Occupation (according to Portuguese Classification of Occupations) and job category (designation and definition of functions given in the law, collective labour regulation instruments, company regulations or in contracts). |
Spain |
The job classification system applied by the company according to the collective agreement which applies to the company or, failing that, by agreement between the company and the representation of workers. In companies with 50 or more employees, i.e. companies obliged to draw up an equality plan, also by groups of jobs of equal value. |
Switzerland |
Under Logib module 1: The functions (job category) do not flow directly into the analysis but are used in order to allocate the two workplace related characteristics: “Professional position” and “Skill level” (qualification level). Occupational skill level (qualification level), the skill level required by the job performed by the employee, a code from 1 to 4 defined as: 1. Extremely demanding and difficult tasks 2. Independent and skilled work 3. Work requiring professional/technical skills 4. Simple and/or repetitive tasks. Professional position, the professional position of the job performed by the employee, a code from 1 to 5 defined as: 1. Senior management 2. Middle management 3. Lower management 4. Lowest management 5. Employees with no management function. |
*New Zealand and Latvia’s rules apply only to the public sector.
Note: Table summarises lists the job classification systems used/suggested for use in countries where gendered pay information must be further disaggregated by job categories.
Source: OECD Gender Pay Transparency Follow-Up Questionnaire (OECD GPTQ 2022, see Annex A).
National job classification systems suggested to employers include the Australian and New Zealand Standard Classification of Occupations (ANZSCO); the Employment Equity Occupational Groups (EEOGs), based on Canada’s National Occupational Classification; the DISCO‑08 code, i.e. the Danish version of ISCO‑08 with an additional tier that further specifies job functions; and the Portuguese Classification of Occupations.
Pay reporting regulations often allow employers to choose between two or more job classification systems. In Austria, for example, employers can use either the company’s job classification system or sectoral collective agreements. In the New Zealand public sector, employers can use the ANZSCO or opt for roles relevant within the organisation. In France, categories of equivalent positions are used. These either correspond to the predefined socio-professional categories (blue‑collar workers; white‑collar workers; technicians and supervisors; engineers and managers) or to another alternative categorisation, although most companies use the predefined system (Briard, Meluzzi and Ruault, 2021[10]).
In Portugal, in contrast, employers must disaggregate pay information by both the standard classification system and by job categories defined in the company or in collective agreements, while in Belgium, the employer must give priority to the sectoral job classification. If a sectoral job classification applies, the job classification at company level should not contain any provisions that conflict with the sectoral collective agreement.
3.2.2. Occupational segregation and the risk of embedding unequal pay
Job classification schemes seek to assess objectively the knowledge, effort, responsibilities, working conditions, education, and difficulty of specific jobs. Yet correctly defining which jobs and responsibilities are “of equal value” is not straightforward. The “value” of different jobs today reflects broader historical, societal, and cultural factors. Job classification schemes can therefore also be influenced by societal biases and gender stereotypes – which, in turn, can embed systematically lower pay in some job categories (Acker, 1989[11]).
The principal risk is that jobs that are traditionally performed by women may be undervalued and underpaid compared to jobs that are traditionally performed by men, even if they require similar levels of skill, effort, and responsibility.
Analyses on the gender pay gap across different countries highlight various factors that contribute to the pay gap between men and women, with occupational choice being one of the most significant factors (Farrell, 2005[12]; Bettio, Verashchagina and Camilleri-Cassar, 2009[13]; Hegewisch et al., 2010[14]; Georges-Kot, 2020[15]). Men tend to opt for higher-paying sectors, while women tend to work in less lucrative sectors (such as health and social work or teaching) and, more often than men, in part-time roles. This is a result of both employee and employer behaviour: a review of experimental audit studies finds that potential employers discriminate against women in (relatively better-paying) male-dominated occupations, and discriminate in favour of women in (relatively lower-paying) female-dominated occupations (Galos and Coppock, 2023[16]), thereby reinforcing gender segregation.
A study of gender-segregated occupations in the United States illustrates different wage outcomes for male‑ versus female‑dominated jobs. The authors find that female‑dominated occupations are consistently paid less across all skill levels (low, medium, and high)4 (Hegewisch et al., 2010[14]).
Full-time workers in low-skilled, male‑dominated professions earned a median of USD 553/week, whereas those in low-skilled, female‑dominated professions earned a median of USD 408/week. The pay for “mixed” professions – those with greater gender balance – falls in between. The highest paid low-skilled workers in male‑dominated professions earned up to a median of USD 685/week (as “driver/sales workers and truck drivers”), whereas those in female‑dominated professions earned only up to a median of USD 438/week (for “nursing, psychiatric and home health aides”) (Hegewisch et al., 2010[14]).
The differences are more marked among high-skilled full-time workers. Those in male‑dominated professions earned a median of USD 1 424/week whereas those in female‑dominated professions earned a median of USD 953/week (Hegewisch et al., 2010[14]). These occupations include, for instance, computer software engineers for male‑dominated professions and registered nurses or elementary and middle school teachers for female. These jobs require at least three years of post-secondary education (i.e. a bachelor degree or equivalent) in most countries. While these female‑dominated occupations are more likely to be found in the public sector, such pay differences are striking considering that the women’s roles often carry a high degree of responsibility. Decisions of registered nurses could make the difference between life and death, while teachers, of course, are caring for and educating children.
What’s more, there is some evidence that women entering a field can cause wages to drop. A recent study finds that a ten percentage point increase in female workers into an occupational class leads to an eight percent decrease in average male wage and a seven percent decrease in average female wage in the concurrent census year, and an nine percent decrease in male wages and a 14 percent decrease in female wages over ten years. Using a shift-share instrument that takes into account the rise in women’s educational attainment and workforce participation from 1960 to 2010, the study establishes a causal relationship between declining wages and gender (Harris, 2022[17]). Other studies have shown mixed conclusions when looking at job prestige and wages (OECD, 2023[18]).
Gender-neutral and/or gender-sensitive job classification schemes
Gender-neutral job classification schemes are mandated in at least ten OECD countries (OECD, 2021[1]). “Gender neutrality” matters because traditional job classifications can reinforce gender bias in job valuations, making what is traditionally “men’s work” more highly valued than “women’s work” (OECD, 2021[1]). When designed with equal pay considerations in mind, job classification systems can help to achieve equal pay for work of equal value goals (Wagner, 2020[19]). Beyond simply removing gendered connotations from job titles,5 gender neutrality means connecting pay with the objective skills, experiences and responsibilities required in a job category independently of the traditional gender composition of a job category.
In some countries – such as Belgium, Germany, Portugal, the Slovak Republic, and the United States – job classification systems are not mandatory themselves, but when they are used they should be gender-neutral and/or gender-sensitive (OECD, 2021[1]).
Many countries with equal pay auditing mechanisms (see Chapter 4) use job classifications to detect pay disparities, as in Canada, Finland, France, Iceland, Norway, Spain, Sweden, and Portugal (OECD, 2021[1]). For instance, in Iceland, the Equal Pay Standard necessitates that companies create their equal pay system using a job classification system that is free of gender bias. The government also offers a free job classification tool for employers (Chapter 7). Following the transition from a voluntary to a mandatory Equal Pay Standard (Chapter 6) in Iceland, gender-neutral job classifications have become more common (OECD, 2021[1]).
Similarly, in Norway and Sweden, regulations specify that analysis should concentrate on equal work or on work of similar or equal value, and in Finland and Chile that employee groups should be defined by some objective worker characteristic (e.g. function performed or on the basis of competence) (Table 3.2). In Canada under the Pay Equity Act, regulation specifies that “job classes are determined by the employer, or in the case a pay equity committee has been formed, by the committee, and are made up of positions within the workplace that: 1) have similar duties and responsibilities; 2) require similar qualifications; and 3) are part of the same compensation plan and are within the same range of salary rates” (Table 3.2).
Belgium provides tools like a checklist for ensuring “gender neutrality” in the evaluation and classification of functions for employers6 (Chapter 7).
In Austria, gender-neutral job evaluation has been used to re-evaluate the value of the work of lower-paid cleaners, which previously had separate pay grades for jobs carried out by men and women (Pillinger, 2021[20]). This type of re‑evaluation of job classifications helps to correct bias in grading systems and can promote equal pay for work of equal value.
The EU Pay Transparency Directive should give gender-neutral job classifications a push forward in Europe, calling for gender-neutral job classifications that “include skills, effort, responsibility and working conditions, and, if appropriate, any other factors which are relevant to the specific job or position. They shall be applied in an objective gender-neutral manner, excluding any direct or indirect discrimination based on sex. In particular, relevant soft skills shall not be undervalued.” (Article 4[4]7).
How to address unequal pay for work of equal value?
Identifying which jobs hold “equal value” is difficult when the skills and education required are completely different. Consider the comparison of low-skilled U.S. workers above. It is not immediately obvious why truck drivers should earn nearly USD 250 more per week than nursing, psychiatric and home health aides – but it is also not straightforward to compare them and address this difference. Both types of jobs suffer from worker shortages, and both face occupational risks. One may argue that truck drivers have physically demanding jobs that require them to lift heavy objects – but this is not dissimilar to nursing aides, who often need to lift people with limited physical mobility. And even if there were a difference in physical demands, should physical demands be valued more highly than the significant interpersonal and organisational skills, as well as emotional demands, required in caregiving jobs?
Assessing what constitutes “equal value,” and consequently achieving equal pay for work of equal value, is therefore a complex issue that requires a range of approaches. Pay transparency legislation, including disaggregated reporting using job classification schemes, is an important tool in promoting equal pay for work of equal value. However, it is important to address biases and stereotypes in job classifications and job evaluation processes with a gender-sensitive lens.
The International Labour Organization provides guidance for employers, HR personnel, and social partners on how to implement gender-neutral job classification systems, emphasising the need to analyse the gendered nature of work (ILO, 2008[21]). To mitigate the risk of bias, researchers in the European and Australian contexts suggest ensuring that job evaluators receive adequate training and come from mixed-gender backgrounds (European Parliamentary Research Service, 2015[22]; Workplace Gender Equality Agency, 2012[23]). Wage negotiation and wage setting, including collective bargaining, should routinely integrate gender-neutral job evaluations (Pillinger, 2021[20]). This is arguably more practical at the firm level than at the sectoral level.
Government bodies have an important role to play by checking and verifying job classification systems for embedded gender biases and developing as well as enforcing penalties for non-compliance (Wagner, 2020[19]). If job classification systems actually were gender-neutral and successfully ensured equal pay for work of equal value, it could potentially eliminate the need for pay equity litigation, saving workers and their representatives time and resources (OECD, 2021[1]).
Based on evidence, good practices, and lessons learned from public service unions in Europe and internationally, good practice in gender-neutral and/or gender-sensitive job classification includes (Pillinger, 2021[20]):
Job classification schemes should use a gender-sensitive approach, i.e. they should take into account that women and men have different skills and experiences due to social and cultural factors.
Job evaluations should be based on objective criteria, for instance on the skills, effort, and responsibility required to perform the job. Job evaluation should also be conducted by trained professionals who are knowledgeable about the specific job and the skills required to perform it. This can help to ensure that the value of different jobs is assessed objectively and fairly.
The process of job classification and evaluation should be transparent and inclusive, meaning that workers and/or their representatives should be involved in and informed about the process.
Job classification schemes should be regularly reviewed and updated to ensure that they remain gender neutral and/or gender sensitive. This means that the scheme should be updated to reflect changes in the workforce and the skills required to perform different jobs.
While job classifications, when used, should be designed in a gender-sensitive way, governments and social partners should also ensure that they do not make job classifications overly rigid. Firms need some freedom to set wages in line with productivity and respond to skill demands and supply (OECD, 2018[24]) (OECD, 2021[25]). This again illustrates the value of gender-disaggregated pay reporting, which illuminates gender pay gaps even in the absence of jobs defined as having “equal value”.
Box 3.3. Country highlight: New Zealand’s efforts to assess “work of equal value”
New Zealand’s amendment to the Equal Pay Act 1972 (the Act) in 2020 provides a unique legislative framework which enables employees or unions to raise a pay equity claim directly with an employer. Under the Act, section 2AAC provides the following.
An employer must ensure that –
(a) there is no differentiation, on the basis of sex, between the rates of remuneration offered and afforded by the employer to employees of the employer who perform the same, or substantially similar, work; and
(b) there is no differentiation, on the basis of sex, between the rates of remuneration offered and afforded by the employer for work that is exclusively or predominantly performed by female employees and the rate of remuneration that would be paid to male employees who –
(i) have the same, or substantially similar, skills, responsibility, and experience; and
(ii) work under the same, or substantially similar, conditions, and with the same, or substantially similar, degrees of effort.
This approach considers the historical context of labour markets whereby work performed by women has often been undervalued. By including an explicit mention of female‑dominated work, it opens up avenues to correct for any remaining gender-based undervaluation.
Pay equity claims can be raised by individual employees or unions. They can be individual claims or claims can be consolidated for a particular type of work across a range of employers as long as union members are represented among employees of all employers. In the latter cases, all employees (also non-union members) are represented by unions and covered by the eventual settlement. A drawback of this system is that negotiating and settling pay equity claims is likely to be more difficult without unions. This may be the case in the private sector which has a very low union density.
Importantly, there is a low threshold to raise pay equity claims. It is not necessary to prove that the work is undervalued, rather it only needs to be arguable that the work is undervalued. For this to be the case two criteria must be fulfilled. Firstly, the work must be at least 60% female dominated – either historically or currently. Secondly, there needs to be a few reasons as to why the work might be undervalued, for instance, because it is characterised as women’s work or because the nature of the work involves skills that have been generally associated with women.
The employer and claimant are responsible for undertaking the work assessment set out in the Act if the claim is considered to be arguable. The work assessment requires a gender-neutral assessment of the work that is the subject of the claim, including an assessment of the level of skill, responsibility, effort, experience and conditions involved in the work, and the work of one or more comparators. Comparators can be drawn from male‑dominated work that is the same, or substantially similar to the work that is the subject to the claim, or it could be work that is different. The parties do not have to agree on potential comparators; instead, they can investigate all comparators identified by the parties to the claim. If the work assessment identifies that the work is undervalued, the final step is to agree on a settlement.
Source: Virtual mission between the Secretariat and the Government of New Zealand; (New Zealand Public Service Commission, 2017[26]), Pay Equity Assessment Process Guide, https://www.publicservice.govt.nz/assets/DirectoryFile/Guidance-Pay-equity-assessment-process.pdf.
Box 3.4. Country highlights: Gender-neutral job classifications in practice in Canada and Sweden
Canada
In Canada, under the Pay Equity Act, federally regulated employers in the private and public sectors must follow a five‑step process when conducting their equal pay audits.
1. Employers must identify and group employee positions in order to create job classes.
2. After job classes have been created, employers determine which of them are predominantly male or predominantly female. Job classes can also be considered gender neutral.
3. Following this, employers must assess the “true” value of work for each predominantly male or predominantly female job class based on the skill, effort and responsibility of the work as well as the conditions under which the work is normally performed. Importantly, the regulations specify that the method used to assess the value of work of predominantly male and female job classes must not discriminate on the basis of gender.
4. Employers must then calculate the actual compensation.
5. Equitable wages within the meaning of this law are achieved when all female job classes within a company are compared to male job classes within the company which perform work of equal or comparable value and when compensation of the female job classes are adjusted as is indicated by the comparison.
Sweden
In the equal pay auditing process, also called an “equal pay survey” by Sweden’s National Audit Office, requires employers in both the private and public sectors must determine whether pay differences are directly or indirectly associated with gender (OECD, 2021[1]). This must be done for the following groups of employees:
1. women and men performing equal work,
2. employees performing work that is dominated by women and employees performing work that considered as equal value to such work but is not dominated by women, and
3. employees performing work that is dominated by women and employees performing work that is not dominated by women but that gives higher pay despite the requirements of the work being regarded as lesser.
Source: OECD GPTQ (2022)
3.2.3. Some countries have less specific requirements for defining job categories
In some countries, regulations include a simple list of job categories to be used in pay reporting. For example, in Italy, pay information is reported separately for executives, managers, clerks, and workers (dirigenti, quadri, impiegati, and operai) (see Box 3.5). Belgian reporting rules also offers an option to report by subsidiary function classification (executive, managerial, executive staff). A similar categorisation is also used with France’s socio-professional categories.
Box 3.5. Country highlight: Italy
Italy has had a pay transparency measure, the Equal Opportunities Code, in place in the private and public sectors since 2006. The Gender Equality Act of 2021 amended the reporting requirements, which now apply to private and public employers with 50 or more employees. The code requires the affected employers to submit a report to trade unions and the Regional Gender Equality Advisor every two years before 30 April. Workers too can request information.
This report must include gender-disaggregated statistics on the annual gross overall remuneration (basic salary plus any additional amounts paid to the employee) at the beginning and at the end of the reporting period. Additional amounts are also reported separately. This information must be further disaggregated by job category.
Furthermore, as part of the measure, employers also need to report information on the gender composition of the workforce as well as gender gaps in worked hours (in excess), in hiring, promotion, and termination rates (further detail available) by job category, in training rates, and in days of parental leave uptake. Additionally, companies must report the gender gap in the number of employees receiving subsidies from the government.
The Gender Equality Advisors (GEAs) at the regional level play an important role in evaluating outcomes within companies. GEAs and unions analyse the reports, and if they detect a collective discrimination on the ground of gender, they can ask the employer to set up a plan aimed at removing the discrimination and inform the trade unions. If the employer’s plan is inadequate, the Advisor can act before a court.
In 2018, the Italian Government launched a digital platform for companies to upload their reports directly, making it easier to collect and analyse data at the national level. Companies that fail to submit their report on time may face strict penalties, including fines of up to EUR 2 580 by the Labour Inspectorate. If non-compliance continues for more than 12 months, suspension of any contributory benefits enjoyed by company for one year. In the event of a false or incomplete report, a pecuniary administrative sanction EUR 1 000-5 000 may be levied on the employer.
Source: OECD GPTQ 2022
3.3. Pay information can also be disaggregated by seniority, age, parenthood status and level of education
In addition to job classification, some countries require the disaggregation of pay data by level of seniority (Australia, Belgium, Lithuania, and Portugal, as well as in Switzerland under recommendations8) and/or by the level of education or qualification achieved (Belgium, Finland, Latvia, Lithuania, Norway, Portugal and Switzerland under recommendations, see endnote 8). Age is also a common factor for disaggregation (Australia, Latvia, and Portugal) and is relevant given that gender gaps typically increase over the life course.
Other worker characteristics used to further disaggregate gendered pay data include working location/region (Australia, Canada under the Employment Equity Act, see endnote 2, and Portugal), remuneration/salary group (Austria, Israel and Lithuania), the level of work responsibility (Chile, Finland and Norway), workload, effort, and working conditions (Finland and Norway), and working patterns (Ireland).
Related to this, women tend to take more and longer breaks from their careers to raise children, which slows down their career progression and affects their pay (Georges-Kot, 2020[15]; OECD, 2022[27]; OECD, 2019[28]). As such, the pay gap is not just a gender issue but also a motherhood issue. Women who become mothers tend to work less in the labour market and often9 earn less than women without children, men without children, and men who become fathers – the so-called “motherhood penalty” and “fatherhood bonus” (Harkness and Waldfogel, 2003[29]; Budig and Hodges, 2010[30]; Glauber, 2018[31]; OECD, 2017[32]). This is likely driven in part by discriminatory behaviour by employers, as has been shown in audit studies (Correll, Benard and Paik, 2007[33]). As such, countries should consider disaggregating gendered pay information by parent status.
3.4. Measuring gender wage gaps with an intersectional lens
To fully understand the intersectional nature of gender pay gaps, it is important to be able to examine how gender interacts with factors such as (self-disclosed) race/ethnicity, language, place of birth, and disability status (Cowper-Coles et al., 2021[8]). Unfortunately, however, only a handful of OECD countries systematically collect data on ethnic and racial background.
Pay information is disaggregated by ethnicity and/or race in Canada under the Employment Equity Act and in the public sector in New Zealand (see Box 3.6). The United States collects information on the gender and racial/ethnic composition of job categories by company via reporting requirements of the Equal Employment Opportunity Commission (EEOC).10 While this presents a picture of diversity in workforce composition, the EEOC does not collect wage information and therefore cannot calculate wage gaps with these gender, racial and ethnic data. For more information on gender-disaggregated non-pay reporting, refer to Section 3.5.
Box 3.6. Country highlight: The intersectional approach in New Zealand’s public service
Kia Toipoto, New Zealand’s “Public Service Gender, Māori, Pacific and Ethnic Pay Gaps Action Plan 2021‑24,” requires all agencies and Crown entities (covered by the government Workforce Policy Statement) to publish their own annual pay gap action plans with their own gender, Māori, Pacific and ethnic pay gaps. Although the plan applies only to a subsection of the public sector and covers about 10% of New Zealand’s labour force, it represents a model for developing pay transparency policy with an intersectional lens.
The Plan recognises that common barriers drive all pay gaps, with more targeted action needed to accelerate progress for wāhine Māori, Pacific women, and women from ethnic communities. As such, the Plan has been developed and is being implemented as a partnership between the Public Service Commission, PSA the Public Service Association (employee union), Te Rūnanga o Ngā Toa Āwhina (representing Māori Public Service Association members), PSA Pacific networks, Ministry of Pacific Peoples, Te Puni Kōkiri, Ministry for Ethnic Communities and the Ministry for Women, as well as representatives of disabled, rainbow and pan-Asian employee‑led networks. This means that all voices impacted by this work have been heard in the development process.
Reporting requirements under Kia Toipoto are comprehensive and granular. All public service employers report organisation-wide gender gaps in mean and median pay. Pay gaps are calculated on average base pay, not total remuneration. This approach is more feasible for a public sector regime, considering that there are not many bonuses and/or discretionary elements to pay in the core Public Service.
Pay is further disaggregated by job classification system (occupational role, organisational group), seniority/tenure, ethnicity/race, age, working patterns (career breaks, and part-time/full-time status, and flexible working), performance pay, starting pay, and location of work. However, it should be noted that pay is reported by these worker characteristics only when there are enough male and female employees to compare, as pay gaps are not considered statistically robust for groups of fewer than 20 men and 20 women. This likely means it has more limited impact in the most gender-segregated sectors – which may also be the ones needing greater pay transparency. Data on ethnicity is also not as clear as data on gender, as the disclosure rate for race/ethnicity is 92%.
Source: OECD Secretariat virtual mission with various stakeholders in the Government of New Zealand.
3.5. Required content in non-pay reporting
At least 24 OECD countries also require employers to report non-pay information about their workforce that is broken down by gender – in other words, gender-disaggregated non-pay data. This can be part of their pay reporting regulations or another regulation altogether. These measures and their requirements are summarised in Table 3.3, below.
Some countries, including Germany, Luxembourg, the Netherlands, and the United States, have rules for reporting non-pay information that is broken down by gender, but they do not have regulations in place for reporting on pay. This means that it may be relatively simple for these countries to create mandatory pay reporting schemes by simply adding pay to existing requirements. Although these reporting requirements are an important step toward improving diversity within organisations, the lack of reporting on wages limits meaningful action in addressing gender pay gaps.
Table 3.3. Content required in non-pay reporting in the private sector
For countries with non-pay reporting requirements, this table specifies the name of the measure and the information that needs to be reported according to the non-pay reporting rules.
Country |
Measure |
Non-pay information to be reported |
---|---|---|
Austria |
Same as pay reporting measure. |
Gender gap in number of employees overall and by job category. |
Australia |
Same as pay reporting measure. |
Gender gap in the number of employees overall, promoted, internally/externally appointed, and voluntarily resigned. Gender gap in the number of employees on primary carer’s parental leave (paid and/or unpaid), on secondary carer’s parental leave (paid and/or unpaid), who ceased employment before returning to work from parental leave. Proportion of female and male workers on the board/governing body Gender gap in the number of equity and non-equity partners by WGEA’s standardised manager categories. |
Belgium |
Law of 22 December 1995 (submitting a social balance sheet) and Royal Decree of 30 January 2001 (content). |
Gender gap in number of employees overall and by contract type. Gender gap in worked hours (in excess) and training rates. |
Canada1 |
Same as pay reporting measure, but only under the Employment Equity Act. Note that non-pay reporting requirements also apply to the public sector unlike pay reporting requirements in EEA. |
Gender gaps in number of employees overall, by job category, by salary range and by contract type. Gender gaps in hiring, promotion, and termination (also further disaggregated by employment status, industrial sector, and region). Gender gaps in number of employees receiving bonus and/or overtime pay. Ethnicity gaps: all data is further disaggregated by ethnicity (Aboriginal peoples), disability status, and by (visible) minority status. |
Chile |
Same as pay reporting measure. |
Gender gap in number of employees overall, by job category and by seniority. |
Colombia |
Law 1946 of 2011, Art. 5 |
Gender gap in number of employees overall, by seniority, by salary class, and by contract type. |
Denmark |
Laws in private and public sector revised and strengthened in May 2022, with amendments entering into force 1 January 2023. Private: Companies Act, Annual Accounts Act and various other acts Public: Act on Equality of Women and Men |
Gender gap in number of employees by seniority. |
Finland |
Same as pay reporting measure. |
Gender gap in number of employees by job category. |
France |
Same as reporting measure, Another pay-related indicator results in a score out of 40 points. |
Gender gap in number of individuals who received a raise (excluding promotions) by socio-professional categories SPC. The result of this indicator varies from 0 to 20 points. Gender gap in promotion rates by SPC. The result of this indicator varies from 0 to 15 points. This requirement applies only for employers with more than 250 employees, for smaller employers it is included within the gender gap in individual raise rates. Proportion of female workers receiving a raise in the year after returning from maternity leave. This helps to check whether the legal obligation to catch up on pay when a worker returns from leave has been complied with. The outcome of this indicator is either 0 if no employees received the raises, they were entitled to upon returning, or 15 points if the employer complied with its commitment for all affected employees. Proportion of workers from the less represented gender among the ten highest paid workers. The higher the underrepresentation, the less points are awarded to the employer. This indicator’s output ranges from 0 to 10 points. |
Base de données économiques, sociales et environnementales (BDESE), i.e. Economic, social and environmental database |
Gender gap in the number of employees overall, by job category, by seniority, and by contract type. Gender gap in hiring, promotion, termination, and training rates. Proportion of female and male workers on the Board of Directors. Gender gap in number of employees receiving a bonus (also further disaggregated by job category). Gender differences in age, vacation take up, qualifications, working conditions (health and safety at work), and the balance between professional activity and personal and family life. Note that the reporting requirements under BDESE are highly granular and that most statistical information is further disaggregated by worker characteristics, such as job category, seniority, age, qualifications, etc. |
|
Germany |
Transparency in Wage Structures Act |
Gender gap in number of employees overall and by contract type (full-time and part-time employment). Employers must also report any measures to promote equality between women and men and their impact, as well as any measures to create equal pay for women and men. Employers who apply no measures have to give the grounds for this in their report. |
Ireland |
Same as pay reporting measure. |
Gender gap in the number of employees who were paid bonus remuneration or received benefits in kind. |
Israel |
Same as pay reporting measure. |
Gender gap in number of employees by job category, level of seniority, salary class, and contract type. Gender gap in worked hours (in excess). Share of employees by gender whose wage is lower than the average wage in the workplace, and who are given a supplement to the minimum wage in accordance with an agreement. |
Italy |
Same as pay reporting measure. |
Gender gap in number of employees overall, by job category, by contract type (temporary and permanent employment types, intermittent employment types, smart-working employment, and traineeships). Gender gaps in worked hours (in excess), in hiring, promotion, and termination rates (further detail available) by job category, in training rates, and in days of parental leave. Gender gap in number of employees receiving subsidies from government (i.e. their wages are paid for). |
Japan |
Same as pay reporting measure. |
Employers with 101‑300 regular employees must publish at least one item from either category, employers with more than 300 regular employees must publish at least one item in each category. A. Achievements in providing opportunities for women workers (e.g. Proportion of female employee among (1) newly hired employees, (2) those in managerial positions, (3) those in positions for section chiefs or the equivalent.) B. Achievements related to the development of an employment environment that contributes to balancing work and family (e.g. Disaggregated by gender: the average length of service; the take‑up rates for parental leave; the average overtime hours per month.) The categories differ slightly for public sector employers (see Box 3.7). |
Korea |
Same as pay reporting measure. |
Gender gap in number of employees overall, by job category and by position. |
Lithuania |
Same as pay reporting measure. |
Gender gap in number of employees overall, by job category, by seniority and by salary class. |
Luxembourg |
For all companies with at least 15 employees, every two years |
Gender gaps in hiring, promotion, and training rates. |
Netherlands |
1 January 2022 a new act entered into force to increase a more balanced male/female‑ratio in top positions in the private sector |
Data regarding the male/female‑ratio in (sub)top positions. |
Norway |
Same as reporting measure. |
Gender gap in number of employees overall, by salary class, and by contract type (e.g. employees in unvoluntary part-time employment and number of temporary employees). Gender gap in parental leave. |
Portugal |
Same as pay reporting measure |
From the collected database (Quadros de Pessoal) it is possible to identify at least the following: Gender gap in number of employees overall, by occupation, by education/qualification, by contract type. Gender gap in hours worked (also in excess) |
Slovenia |
Companies Act |
Gender composition in management/supervisory boards |
Spain |
Same as pay reporting measure. |
Gender gap in number of employees overall, by job category, by seniority, by salary class, and by contract type. Gender gap in worked hours (in excess), promotion rates, training rates, days of parental leave. |
Switzerland |
Federal Act on the Amendment of the Swiss Civil Code VII. Gender representation of on the board of directors and in the executive board Art. 734f527 |
Gender gap in number of employees overall. Unless each gender makes up at least 30% of the board of directors and 20% of the executive board, the following must be indicated in the remuneration report of companies that exceed the thresholds in Article 727 paragraph 1 number 2: 1. the reasons why genders are not represented as required; and 2. the measures being taken to increase representation of the less well represented gender. |
United States |
Section 709(c) of Title VII of the Civil Rights Act as amended 42 U.S.C. § 2000e‑8(c), and 29 CFR 1602.7‑.14 and 41 CFR 60‑1.7(a); 1602.22, .27‑.28, .30, .32‑.37, .39 and .41‑.45. (EOO Reports and EEOC Management Directive 715) |
Gender gap in number of employees overall, by job category, by pay plans/grade levels, and by contract type. Gender gap in hiring, termination, and promotion rates. Federal agencies with 500 or more employees: gender gaps in number of employees by seniority, by mission-critical occupations, by awards. Ethnicity gaps: all data is further disaggregated by ethnicity. |
Note: Table summarises non-pay reporting requirements in countries with such requirements. “Same as pay reporting measure” refers to the titles presented in [insert best table for this]. Pay reporting requirements are summarised in Table 3.1.
1. Canada’s pay reporting regulation is two‑fold. Pay gap reporting under the Employment Equity Act applies to federally regulated private‑sector employers with 100 or more employees. These employers submit annual reports to the Minister of Labour by 1 June of each year. Conversely, under the Pay Equity Act, federally regulated employers in both the private (10 employees or more) and public sectors (no employee threshold) are required to submit an annual statement on their pay equity plans to the Pay Equity Commissioner.
Source: OECD Gender Pay Transparency Follow-Up Questionnaire (OECD GPTQ 2022, see Annex A).
Most countries require private sector employers to report gender gaps in the number of employees. This is the most common (non-pay) data required, and it is mandated in Austria, Belgium, Canada, Chile, Colombia, France, Germany, Italy, Korea, Lithuania, Norway, Portugal, Spain, Switzerland, and the United States.
These gender gaps in headcounts are often further disaggregated by job category, as in Austria, Australia, Canada, Chile, France, Italy, Korea, Lithuania, Portugal, Norway, Spain, and the United States; by contract type, as in Belgium, Canada, Colombia, France, Germany, Italy, Portugal, Norway, Spain, and the United States; and less often, by salary class (see Figure 3.1 for an overview of country counts).
Other commonly reported non-pay gender-disaggregated data include gender differences in hiring, termination, and promotion rates (Canada, Italy, Luxembourg, and the United States, with promotion rates also required in Australia and France) and worked hours (Belgium, Canada, Italy, and Norway). These are in line with the proposed requirements in the EU Directive (see Chapter 2).
Japan applies an approach tailored to company size and, presumably, capabilities. As part of wage gap reporting rules, Japan requires employers to report several non-pay gender disaggregated statistics depending on sector and size in terms of number of employees (see Box 3.7).
The United States11 does something similar: federal agencies are required to report the number of employees by gender, race/national origin, and disability within the Senior Executive Service (SES), within each salary plan and grade level.
Box 3.7. Country highlight: Japan
In Japan, based on the Act on Promotion of Women’s Participation and Advancement in the Workplace from July 2022, private sector employers with 301 or more employees are required to report on gender-disaggregated pay information on a yearly basis
The reporting includes the proportion of female workers’ annual salary (severance pay and commuting allowance can be excluded) relative to that of male workers, disaggregated by regular and non-regular worker status
A. Achievements in providing opportunities for women workers (e.g. the proportion of female employees among (1) newly hired employees, (2) those in managerial positions, (3) those in positions for section chiefs or the equivalent).
B. Achievements related to the development of an employment environment that contributes to balancing work and family (e.g. disaggregated by gender: the average length of service; the take‑up rates for parental leave; the average overtime hours per month).
Private sector employers with 101‑300 regular employees must publish at least one item from either category (A or B), while private sector employers with more than 301 regular employees and public sector employers must publish at least one item in each category (A and B). The categories differ slightly for public sector employers.1
Results of the reporting process in the private sector must be shared publicly on corporate websites or on the website run by the Ministry of Health, Labour, and Welfare, which includes a database of firms that promote women’s participation and advancement
The Minister of the Ministry of Health, Labour, and Welfare and the head of local labour bureaus in each prefecture are responsible for enforcing the reporting rules. The legislation does not specify penal sanctions for non-compliance, but the names of the enterprises breaching the law can be publicised by the minister or the head of local bureaus.
1. A. (Public) Proportion of female employee among (1) newly hired employees, (2) those in managerial positions, (3) for each different position. B. (Public) Disaggregated by gender: the turnover rates in a given fiscal year; the take‑up rates for parental leave; the duration of parental leave. Note that the timing of revision and enforcement is different for systems covering the public sector and for systems covering the private sector Regarding public sector, the order was amended in December 2022, and took effect from April 2023.
Source: OECD GPTQ 2022
3.5.1. Many countries are interested in gender composition of top positions
In OECD countries, women make up around one‑third of managers on average (OECD, 2021[34]). Women also hold just slightly below 30% of seats on the boards of the largest public businesses (OECD, 2022[35]). This is related to the “leaky pipeline” to top jobs – in short, the number of women who can advance to leadership positions later in their career is much smaller than the number who enter the workforce in the first place, in large part due to career interruptions related to unpaid caregiving.
To help address vertical segregation, many countries’ regulations require non-pay reporting to concentrate on gender differentials in the top positions of companies. For instance, Slovenia’s non-pay reporting measure requires companies to report on the gender composition in management/supervisory boards, and in the Netherlands, companies must provide data regarding the male‑to-female‑ratio in (sub)top positions. In France, the Professional Equality Index12 includes an indicator which is calculated based on the proportion of workers from the less represented gender among the ten highest paid workers. Switzerland has a specific auditing process for companies with unequal representation of the two genders in top positions (see Box 3.8).
Furthermore, Australia, Chile, Colombia, Denmark, Korea, Lithuania, and Spain require employers to report the number of employees by gender and by seniority.
Box 3.8. Some countries with non-pay reporting requirements also have company auditing procedures
Germany
For instance, as part of Germany’s gender-disaggregated non-pay reporting requirements,1 companies with more than 500 employees must publish information on “any measures to promote equality between women and men and their impact, as well as any measures to create equal pay for women and men. Employers who apply no measures have to give the grounds for this in their report.” Furthermore, this report must contain figures disaggregated by gender on the average total number of employees, as well as the average number of full-time and part-time employees.
Additionally, there is also a gender auditing process.2 This is not a legal obligation, but rather certain companies are called upon by the Transparency in Wages Act to conduct an internal fact-finding procedure to review the current remuneration provisions, remuneration components, and job evaluation systems – but not statistics on wage gaps. These procedures are then evaluated, and their implementation is assessed with an eye toward compliance with the principle of equal pay within the meaning of the Act.
The results of these audits are shared with works councils and employees. The lack of penalties for non-compliance has been identified as a drawback of Germany’s overall auditing strategy (Aumayr-Pintar, 2019[36]), but the absence of reporting on actual pay differences in Germany likely limits the effectiveness of reporting.
Switzerland
Switzerland’s regulations require a type of auditing process. The rules specify that all relevant employers for which the less represented gender makes up less than 30% of the board of directors and less than 20% of the executive board must indicate in their remuneration report: “the reasons why genders are not represented as required; and the measures being taken to increase representation of the less well represented gender.” In Switzerland these rules complement the requirement to report and analyse pay information.
1. See the Transparency in Wage Structures Act (Entgelttransparenzgesetz) at https://www.bmfsfj.de/bmfsfj/themen/gleichstellung/frauen-ndarbeitswelt/lohngerechtigkeit/entgelttransparenzgesetz/entgelttransparenzgesetz-117952.
2. This is referred to as “Internal company procedures to verify and establish equal pay” in the Transparency in Wage Structures Act, Part 3.
Source: (OECD, 2021[1]), Pay Transparency Tools to Close the Gender Wage Gap, https://doi.org/10.1787/eba5b91d-en, OECD GPTQ 2022
3.6. Pay transparency in job postings and advertisements
Pay transparency in job postings refers to the practice of openly disclosing the salary or salary range for a job position. This offers job applicants and employees a clearer understanding of what they can expect to earn in a given role. Salary range transparency laws can erase the culture of pay secrecy, help women (and men) better negotiate their salaries, reduce the gender (and other) pay gaps, as well as improve women’s economic security over their lifetime (Center for American Progress, 2023[37]).
3.6.1. EU Pay Transparency Directive
Recognising the potential gender equality value of presenting pay ranges in job advertisements, the EU Pay Transparency Directive grants the right to pay transparency before starting a job. This includes the following:
1. Applicants should be provided with information about the initial pay or pay range for the position they are applying for, based on objective criteria that are not biased by gender. This information should also include any relevant provisions of the collective agreement that apply to the position. The information should be made available in a way that promotes transparency and allows for informed negotiations on pay, such as through a job vacancy notice before the interview or by other means.
2. Employers are prohibited from asking applicants about their previous or current pay history in their past employment relationships.
Employers must ensure that job vacancy notices and job titles are gender-neutral and that the recruitment process is conducted without discrimination. This is to protect the right to equal pay for equal work or work of equal value.
Some EU countries, such as Austria, already require the disclosure of salary range in job advertisements.
3.6.2. State-level policies in the United States
Eight states have enacted salary range transparency laws across the United States in recent years: California, Colorado, Connecticut, Maryland, Rhode Island, and Washington (Center for American Progress, 2023[37]). Colorado was the first state that implemented this type of pay transparency requirement. This and the requirements in California, New York, Rhode Island, and Washington are summarised below. States considering passing such transparency laws include Hawaii, Illinois, Kentucky, Massachusetts, Montana, New Jersey, Oregon, South Dakota, Vermont, Virginia, Washington D.C. (Center for American Progress, 2023[37]).
3.6.3. California
California has amended their Labour Code such that, as of January 1st 2023, employers with 15 or more employees need to write salary ranges on job advertisements. This is the case whether the advertisement is found on a company’s hiring page or a third-party website, such a job board website (Cain, 2022[38]).
California is the largest state in the United States with pay transparency in job postings: these rules will affect 19 million workers, and almost 200,000 employers (among which are large and influential companies such as Apple, Disney, Google and Meta (Cain, 2022[38]). This may have downstream consequences in changing norms in this sector globally (Leung, 2022[39]).
3.6.4. Colorado
In January 2021, Colorado passed a then-novel law, the Equal Pay for Equal Work Act, which requires employers to include compensation information in their online job postings. At the time, Colorado was the only state in the US that had implemented this type of pay transparency requirement (Bruner, 2022[40]).
3.6.5. New York
New York’s pay disclosure in job advertisements law is similar to Colorado's, and mandates companies with more than four employees to display salary ranges. It was originally scheduled to take effect on May 15, 2022, but was postponed to November 2022 due to opposition from businesses. The revised law only applies to hourly and salaried positions that are performed physically in New York City, highlighting the contentious nature of this legislation (Bruner, 2022[40]).
Similarly to California, New York’s pay transparency legislation holds considerable influence due to the dominant banking industry. Other banking industries across the world may follow in New York’s footsteps and also set up pay transparency in job postings (Leung, 2022[39]).
3.6.6. Rhode Island
While the amended Pay Equity Act in Rhode Island does not mandate employers to post pay ranges on job ads, businesses are obligated to provide the range to job applicants if requested. Employers must reveal the minimum and maximum salary range before discussing compensation with the candidate during the hiring process, and again if the employee changes their position within the organisation. Additionally, employers must provide the salary range for a current employee's position upon request (Cain, 2022[38]).
Box 3.9. Key terms and definitions in this report
A comparator, in the context of equal pay litigation, refers to a worker whose salary is used as a reference for another person who is in a comparable working situation. Guidelines as to who qualifies as a comparator (and whether a comparator is necessary to prove pay discrimination) vary by country (Chapter 1). A comparator may be real or hypothetical.
Equal pay for work of equal value implies that women and men should get equal pay if they do identical or similar jobs, and that they should also earn equal pay if they do completely different work that can be shown to be of equal value when based on “objective” criteria. These objective criteria tend to encompass job-related characteristics such as skills, effort, levels of responsibility, working conditions and qualifications. Many countries have attempted to clarify the use of the concept of “work of equal value” in national legislation.
An equal pay audit is a process conducted by an employer or external auditor that should include an analysis of the proportion of women and men in different positions, an analysis of the job evaluation and classification system used, and detailed information on pay and pay differentials on the basis of gender. An equal pay audit is more intensive than simple pay reporting. A pay audit should make an effort to analyse any gender pay gaps found, should attempt to identify the reasons behind these gaps, and could be used to help develop targeted actions on equal pay.
Horizontal segregation refers to the concentration of women and men in different sectors and occupations. For example, women are typically overrepresented in childcare and men are typically overrepresented in engineering.
Intersectionality1 is a term used to describe how social and political identities, such as race, gender, class, sexual orientation, and ability, intersect to create unique experiences of discrimination and privilege. The concept of intersectionality acknowledges that individuals can experience various forms of oppression and discrimination simultaneously, and that these experiences cannot be fully understood or addressed by considering only one aspect of their identity in isolation.
Job classifications are related to job evaluation processes and commonly entail human resource personnel and/or social partners ranking each job within an organisation against objective criteria that relates to the required skills, effort, responsibilities, working conditions, education, and difficulty of a role, amongst other observable characteristics. Related to this, gender-neutral job classification systems refer to job classification systems that account for the gender predominance of a given job class and categorise work based on the same objective criteria for men and women (Chapter 3).
Gender-neutral or gender-sensitive job classification systems refer to a framework for categorising jobs that avoids gender bias and is based on objective criteria. The aim is to eliminate gendered assumptions and stereotypes about what type of work is suitable for men or women. These systems typically use a set of factors, such as skill level, responsibility, and working conditions, to determine the appropriate job classification. The use of gender-neutral job titles is an aspect of this system, such as using “police officer” instead of “policeman” or “firefighter” instead of “fireman.”
The OECD Gender Pay Transparency Questionnaire 2022 (OECD GPTQ 2022, presented in Annex 1) is the reference questionnaire for the policies presented and discussed in this report.
Pay reporting refers to policies mandating that employers regularly report (including to employees, workers’ representatives, social partners, a government body, and/or the public) gender pay gap statistics. Such statistics typically include the average or median remuneration of men and women at the company or workplace level but are often more detailed and include breakdowns by groupings such as job category.
Pay transparency is an umbrella term referring to policy measures that attempt to share pay information in an effort to address gender pay gaps. Such measures may include mandating pay reporting, equal pay auditing, job classification systems, and publishing pay information in job vacancies.
Vertical segregation refers to the concentration of women and men at different levels of an organisational hierarchy, e.g. at different grades, levels of responsibility or positions.
1. This first originated with Crenshaw (1989[41]).
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Notes
← 1. New Zealand requires gender pay gap reporting only in the public sector; there are currently no requirements in place for pay gap reporting in the private sector. While this report principally focuses on private sector pay gap reporting rules, New Zealand is occasionally presented in this report for its novel practices in pay transparency for the public sector.
← 2. Canada’s pay reporting regulation is two‑fold. Pay gap reporting under the Employment Equity Act applies to federally regulated private‑sector employers with 100 or more employees. These employers submit annual reports to the Minister of Labour by 1 June of each year. Conversely, under the Pay Equity Act, federally regulated employers in both the private (10 employees or more) and public sectors (no employee threshold) are required to submit an annual statement on their pay equity plans to the Pay Equity Commissioner.
← 3. The treatment groups were exposed to the following interventions: 1) the gender pay gap (GPG) presented as percentage and visually in a bar chart; 2) identical to 1st but with benchmarking (against other companies) information; 3) identical to 2, but GPG presented in terms of money and visually as coins; 4) GPG presented as percentages in the type of the UK Energy Performance Certificate. The control group only saw the percentage difference GPG.
← 4. Male‑dominated occupations are defined as those in which 25% or fewer workers are female, and female‑dominated occupations are defined as those in which 25% or fewer workers are male. Wages are from 2009.
← 5. Interestingly some languages, like Finnish, already have no gender connotation. The Finnish language offers an example of gender neutrality due to its structure and vocabulary. Unlike many other languages, Finnish does not have grammatical gender distinctions for nouns. This absence of gendered nouns means that there are no inherent linguistic gender biases or connotations associated with specific words. Finnish also lacks gender-specific pronouns like “he” or “she”. Instead, it uses a single gender-neutral pronoun, “hän,” which can refer to both males and females. This absence of gendered language could help remove potential assumptions related to job titles and allow for a more objective, gender-neutral evaluation of skills, experiences, and responsibilities in job categories.
← 6. Available at https://emploi.belgique.be/fr/actualites/check-list-non-sexisme-et-classification-des-fonctions.
← 7. The European Union Pay Transparency Directive is available at https://www.europarl.europa.eu/doceo/document/TA-9-2023-0091_EN.html#title2.
← 8. When the gender pay gap analysis is conducted with the Swiss Confederation’s standard analysis tool, gender gaps are disaggregated further by education, seniority, potential work experience, level of qualifications and professional position.
← 9. In the United States, for example, the motherhood penalty has been found to be larger among lower skilled/lower earning workers than for more highly skilled/earning workers (Budig and Hodges, 2010[30]; Killewald and Bearak, 2014[42]; Glauber, 2018[31]).
← 10. For more information on reporting requirements of the US government, see http://eeocdata.org/eeo1.
← 11. Equal Employment Opportunity Commission Management Directive 715 (MD‑715) is policy guidance for federal agencies to establish and maintain effective EEO programs, as required by Title VII of the Civil Rights Act of 1964 and the Rehabilitation Act of 1973.
← 12. Index de l’égalité professionnelle, more information available at https://travail-emploi.gouv.fr/droit-du-travail/egalite-professionnelle-discrimination-et-harcelement/indexegapro.