Global gender pay gap audits comparative table

Country

Company threshold

Reporting requirements

Publishing
Requirements

Frequency of reporting (years)

Key dates

Third party review

Consequences for non-compliance

Canada (federal only)

100+ (employment equity reports);

10+ (equity plans)

Employers must produce an employment equity report recording salary data and include aggregated wage gap information on hourly pay gaps, bonus pay gaps; overtime pay gaps; and overtime hours worked gaps in their annual employment equity report.

Employers must establish a pay equity plan to identify and rectify compensation differences between men and women. Employers must identify similar positions that make up a job class; ascertain whether each job class is more than 60% male, more than 60% female or gender neutral; determine the value of work of each predominantly female or male job class; calculate the total compensation of each predominantly female or male job class and compare the compensation between predominantly female and male job classes doing work of equal or comparable value.

There is an online tool that provides data on pay gaps for each employer.

1 (employment equity reports);

5 (equity plans)

Employment equity reports must be filed by 15 May each year.

For most employers, equity plans need to be established by 3 September 2024. They must be updated every five years.

Employment equity reports must be reported to the Minister of Labour.

Fines of up to CAD 50,000 for not meeting equity employment report requirement.

The Pay Equity Commissioner ensures compliance with statutory provisions with pay equity plans and may order certain action be taken, administer monetary penalties, or publish the names of employers in violation.

Finland

30+

Gender equality measures based on a gender equality plan. Plan must include a survey of the grades of jobs performed by women and men, the pay for those jobs and any differences in pay. Pay survey must involve the compilation of statistics. The plan must include measures aimed at achieving gender equality in pay.

No. Employers may choose to do so. However, employees and their representatives have a right to access pay discrimination information under certain circumstances.

2

No key dates relevant to calculation, compilation or delivery of the equality plan/survey/statistics.

Employees and their representatives have a right to access information that can be used to assess if pay discrimination on the ground of gender has occurred, under certain circumstances.

France

50+

Employers must calculate their "index of occupational equality between women and men" and publish their score (out of 100). A company's index is based on 4 indicators for companies with 50 to 250 employees and 5 indicators for companies with 250+ employees. The 4 common indicators are:

• gender pay gap based on the average remuneration of female employees compared with male employees, broken down by age group and job category;
• percentage of female employees and of male employees who received a pay increase during the year concerned, broken down by job category;
• percentage of female employees who, during the year concerned, received a pay increase after returning from maternity leave; and
• number of women and of men among the 10 highest paid employees.
  
  The additional indicator in companies with more than 250 employees is the percentage of female employees and of male employees who received a promotion during the year concerned.

Yes. Relevant employers must publish their occupational equality index score for the previous year and the scores for each indicator on their website. Employers must also report  scores online to the Ministry of Labour and provide all relevant information to the company's social and economic committee.

If a company achieves less than 85 points, it must set progress objectives in respect of each indicator for which it did not achieve a maximum score. These objectives must be published on the company's website alongside the index scores until its score reaches 85 points.

1

By 1 March.

If a company achieves an occupational equality index score of less than 75 points, it must negotiate with trade unions on adequate corrective measures and, where necessary, a programme of "catch-up" pay increases over one or more years for the underpaid sex.

Iceland

25+

Equal pay certification. Certification entails a written statement from the certifying body that states that the equal pay system and its implementation meet the required standards (following an audit by the certifying body). As part of the certification, employers must average pay differences.

Published on their website.

All companies with 25 employees or more must have acquired certification by 1 January 2022. Equal pay certification must be renewed every three years.

Information not available.

An external  certification body conducts an audit on the employer's analysis.

Ireland

150 (50 in 2025)

Employers must report on, among other things, the difference between the mean/median hourly remuneration and mean/median bonus remuneration of male employees and that of female employees, and the respective percentages of all employees within each of the remuneration quartiles (lower, lower-middle, upper-middle and upper quartiles) who are male and female. This information is provided for different contractual arrangements, eg temporary, part-time and those who receive benefits in kind.

Employers must set out the reasons for the differences, as well as the measures taken to eliminate or reduce the gender pay.

Employer's website or in some other way that is accessible to all its employees and to the public. The reasons for any pay gap and any measures taken to eliminate the pay gap must be stated in the annual report.

1

Relevant employers must choose a relevant date. This snapshot date may be any day in June. The data on which the reporting is based must relate to the 12-month period ending on the snapshot date.

Employers are not required to submit their gender pay gap reports to the government or any public authority. The Government plans to develop an online reporting system, with a central portal where all reports will be uploaded and can be accessed by the public.

Norway

50+ (or if requested by the majority of employees in companies that employ between 20 and 50 employees on a regular basis), and all public companies.

Survey of wage differentials between genders and a statement concerning current and future gender equality efforts.

Statement must be included in the company's annual report or similar document available to the public. Public undertakings which are not subject to a duty to prepare an annual report must include the statement in another report/document available to the public and issued annually.

Investigation including a survey on wage differentials is every 2 years. Statement on gender equality published every year.

Statement on gender equality published every year.

Annual reports must be approved by the general meeting within six months after the end of the financial year. The end of the financial year is 31 December, so the deadline is 31 July (if the statement is issued in the annual report). After the annual reports have been approved, companies have one month to forward the reports to the Register of Company Accounts.

The board of directors of limited liability companies and public limited liability companies must ensure compliance.

Portugal

50+

Employers must submit their pay data to the government. The inspectorate of labour ministry notifies the employer of any pay discrepancies within 60 days of receiving the data.

The ministry responsible for labour matters publishes gender pay gap between women and men broken down by

by company, profession and qualification level, as well as general and sectoral information on pay differences between women and men. This is published in the first half of each year. The ministry keeps the information available and updated on its website.

1

Information not available

Along with re reporting obligations, employer have a transparent remuneration policy. The competent entity in the area of equal opportunities between men and women can give an opinion on the existence of remuneration discrimination, at the request of the worker or trade union representative.

Spain

Payroll register - all;

Equality plan - 50+, have an obligation to adopt an equality plan under the applicable collective bargaining agreement, or must do so to comply with disciplinary proceedings taken by the labour authority

The payroll register contains information on the salaries of a company's employees, which is segmented by gender and professional groups, professional categories or jobs of equal value). If the average or median total remuneration in the company for workers of one gender is at least 25% higher than that of the other gender, the payroll register must include a justification that this difference is due to reasons other than the gender of the workers.

The equality plan includes an assessment (diagnosis) of the remuneration situation at the company and pay audit.

The payroll register must be public. The registration of the equality plan is compulsory. The registration allows public access to the content of the equality plans.

The payroll register is done annually. It is mandatory to have the previous year's register before the end of the current year. Equality plans must be valid for a fixed period, which may not exceed four years.

Information not available.

Employees' representatives must be consulted at least 10 days in advance of the preparation of the payroll register. Where there are no employee representatives, the employees can access information on the percentage differences of the average pay of men and women. A specific commission to oversee and monitor the plan must be created, made up of company representatives and workers' representatives.

Fines (for infringements related to the payroll register and equality plans)

Sweden

10+

Employers must conduct a wage survey and analyse their provisions and practices regarding pay and other terms of employment, and pay differences between women and men performing equal work or work of equal value. Employers must draw up an action plan that covers equal pay and reports the results of the wage survey. An employer with at least 10 employees must document in writing its report of the wage survey and its active measures concerning wages.

No

1

Information not available.

Employers must provide any trade union to which they are bound by a collective agreement with the information that it needs to cooperate in the survey and, where relevant, the creation of an action plan for equal pay.

The Equality Ombudsman may order employers to fulfil obligations in relation to wage surveys.

Switzerland

100+

Internal equal pay analysis (government provides free tool to aid the analysis)

Companies listed on a stock exchange are obliged to publish the result of the analysis in the notes of their annual report and accounts.

4

First equal pay analysis was due by 30 June 2021. The analysis must be repeated every four years unless the number of employees falls below 100, or the employer has shown in an earlier analysis that equal pay has been achieved.

The employer must inform their employees in writing of the result of the equal pay analysis within one year of completing the review.

Although the federal government does not carry out an inspection the analysis must be reviewed and verified by an independent body.

There are no sanctions or mandatory measures in the event of a breach of the obligation to analyse wage equality or if a gender-specific pay gap is established. The employer is, however, obliged to carry out the equal pay analysis again after four years.