Pay Transparency in Progress

Annex C. Information about pay reporting measures in the public and private sectors

Table A C.1. Summary of OECD countries’ pay reporting rules in countries with mandatory reporting in the private sector and/or public sector, July/August 2025

Country	Name of measure	Year	Affected sectors	Size (cut-off number of employees)	Other criteria	Frequency of reporting (in years)	Pay audits
Austria	Private: Equal Treatment Act, §11a. Public: Federal Equal Treatment Act, §6a.	2011 amendment	Private and public, rules same unless otherwise indicated	150	No	Private: 2 Public: 1	Not mandated
Australia	Workplace Gender Equality Act and subordinate instruments	2021; 2022 and 2023 amendments	Private and public (the Commonwealth)	100	No	1	Not mandated
Belgium	Gender Pay Gap Act	2012	Private	50	The regulations provide for a full form and a short form for reporting depending on whether the number of workers is 100 or more or 50 or more.	2	Not mandated
Canada	Employment Equity Act (EEA) Pay Equity Act (PEA)	EEA: 2021 amendment PEA: 2021	EEA: Private Note that under EEA non-pay reporting requirements also apply to the public. PEA: Private and public	EEA: 100 PEA: 10	EEA: Applies only to federally regulated private‑sector employers, federally regulated Crown corporations, and other federal organisation. PEA: Applies to federally regulated private and public sector employers, parliamentary workplaces, and the Prime Minister’s and ministers’ offices.	EEA: 1 PEA: 3 initially, then 1 for pay surveys and 5 for pay audits.	EEA: Not mandated, but any formal or informal policy or practice with a disproportionately negative impact on members of designated groups, including pay gaps, must be assessed for the presence of employment barriers. PEA: Mandated
Chile	General Standard (NCG), No. 386	2015	Private	Not applicable, the requirement to report does not depend on size.	Applies to entities supervised by the Financial Market Commission (CMF) (see endnote 3), i.e. corporations and/or public companies that are issuers of publicly traded securities or open stock corporations.	1	Not mandated
Denmark	Equal Pay Act	2008 amendment	Private and public	35 with at least 10 from each sex in same work function.	Does not apply to employers covered by collective agreements with equal pay obligations. Does not apply to employers in the industries: agriculture, horticulture, forestry and fishing.	1	A voluntary alternative to complying with the gender pay gap reporting mechanisms
Finland	Equality Act	2014 amendment	Private and public	30	Applies to companies that exercise the authority of an employer as referred to in the Employment Contract Act (55/2001).	2	Mandated if the analysis of different employee groups of the pay survey reveals clear pay differences between women and men.
France1	(i) Labour Code (ii) Decree n°2019‑2015 (iii) Order of 17 August 2022 (iv) Decree n°2019‑382 (v) Decree n°2021‑265 (vi) Decree °2022‑243 (vii) Decree n°2023‑623	(i) 2018 amendment (ii)-(iv) 2019 (v) 2021 (vi) 2022 (vii) 2023	Private and public	50 Requirements differ for those employers with more than 250 employees.	Companies that cannot calculate all portions of the Index are excluded. As far as public employers are concerned, public establishments of an industrial and commercial nature and certain public departments and administrative establishments employing at least 50 employees are subject to the obligation to publish the Index. Local authorities and public establishments of inter-municipal co‑operation with more than 40 000 inhabitants, the National Centre for the Territorial Civil Service and other designated establishments are also subject to this obligation. Health and medico-social establishments are included in reporting.	1	Mandated
Iceland	(i) Act on Equal Status and Equal Rights Irrespective of Gender, Art. 7 and 8 (ii) Equal Pay Standard (certification)	(i) 2020 amendment (ii) 2018	Private and public	25	No	3	Mandated
Ireland	Gender Pay Gap Information Act	2022	Private	50	Applies to companies formed and registered under the Companies Act of 2014 or an existing company within the meaning of that Act.	1	Mandated
Israel	Male and Female Workers (Equal Pay) Law 5 724‑1 964	2022 amendment	Private and public	518	Applies also to persons required to report under legislation specified in section 6A (i.e. Budget Basics Law No. 5 745‑1985, section 33; Associations Law No. 5 754‑1980, section 36(b); Securities regulations 1970, section 21; General Water and Sewage Corporations No. 5 710‑2010, section 11(5)).	1	Not mandated
Italy	Equal Opportunities Code (Decree No. 198/2006), Art. 46 Procedure laid down in Interministerial decree of June 2024	2021 amendment	Private and public	50	No	2	Not mandated
Japan	Act on the Promotion of Women’s Active Engagement in Professional Life	2025 amendment	Private	301 101 in 2026	No	1 (Report within approximately three months after the end of the fiscal year)	Not mandated
Korea2	Equal Employment Opportunity and Work-Family Balance Assistance Act, as amended by Affirmative Action	2020 amendment	Private and public, rules same unless otherwise indicated	Private: 500 (300 or more full-time employees for companies that are obliged to provide disclosure in accordance with Article 14 of Monopoly Regulation and Fair Trade Act) Public: Not applicable, the requirement to report does not depend on size.	No	1	Not mandated
Latvia3	Law on Remuneration of Officials and Employees of State and Local Government Authorities	2018 amendment	Public only	N.A.	No	Monthly	Not mandated
Lithuania	Labour Code, Art. 23(2)	2017	Private and public	20	No	1	Not mandated
Norway4	Equality and Anti-Discrimination Act, Section 26(a)	2020 amendment	Private and public, rules same unless otherwise indicated	Private: 50 Public: Not applicable, the requirement to report does not depend on size.	Also applies to employers that ordinarily employ between 20 and 50 persons if requested by the employees or employee representatives.	2	Mandated
Portugal	(i) Ordinance No. 55/2010 (ii) Law on Equal Pay (No. 60/2018)	(i) 2010 amendment (ii) 2018	Private	Not applicable, there is no size threshold for pay reporting. All employers must submit the Single Report (see endnote 8).	If pay differences are found, employers with 50 or more employees are subject to potential follow-up requirements. This regime applied, during the two first years of validity of the law, to companies with 250 employees or more and from the third year of validity of the law onwards, to companies with 50 employees or more.	1	Mandated
Spain	(i) Workers Statute, Art. 28.2 (ii) Royal Decree 902/2020, Art 5&6	(i) 2019 amendment (ii) 2020	Private	Not applicable, the requirement to report does not depend on size (see endnote 7).	Also applies to companies compelled by a collective agreement or a decision of the labour authority. Companies of 50 or more employees must show more information (data about work of same value) in their registry and develop and implement an equality plan.	Pay reporting: 1 Pay audit: Linked to schedule in company’s equality plan.	Mandated
Sweden	Discrimination Act 567	2014 amendment	Private and public	Not applicable, the requirement to report does not depend on size (see endnote 9).	Employers with more than ten employees need to document their work on pay audits.	1	Mandated
Switzerland5	Swiss Federal Act on Gender Equality	2020 amendment 2032 sunset clause	Private and public	100	No	If the analysis indicates that equal pay requirements are being met, once. Otherwise, 4.	Mandated
United Kingdom	(i) The Equality Act (ii) Regulations	(i) 2010 (ii) 2017	Private and public	250	No	1	Employment Tribunals are required to order employers to conduct equal pay audits if they lose an equal pay claim at tribunal.

Note: Table 2.1 summarises the key features of reporting requirements in countries with such requirements in the public and/or private sectors. The year presented refers either to the year of introduction of the measure, of the most recent amendment (amend.), or of their entry into force. The content required in pay reporting and auditing processes varies across OECD countries. This is discussed in further detail in Chapter 3.

1. France has a series of public decrees outlining these reporting rules. France’s related regulatory framework includes Labour Code: Articles D1142‑4 to D1142‑14 and L1142‑8 to L1142‑10 and L2242‑8; Degree on the application of provisions aimed at eliminating pay gaps between women and men in the company; Order defining the presentation models and the methods for transmitting to the administration the indicators and the results in terms of the pay gap between women and men in the company; Decree on the application of provisions of Art. 104 of Law n°2018‑771 for the freedom to choose one’s professional future relating to professional equality obligations between women and men in the enterprise; Decree relating to measures aimed at eliminating pay gaps between women and men in the company and on the application of provisions of Art. 244 of Law n°2020‑1 721 on finance for 2021; Decree relating to measures aimed at eliminating pay gaps between women and men in the company provided for by Art. 13 of the accelerate economic and professional equality and by Article 244 of Law n°2020‑1 721 of 29 December 2020 on finance for 2021 (OECD GPTQ, 2022).

2. Korea: An enterprise group subject to disclosure refers to a group of companies with total assets of 5 trillion won or more, and it is designated by the Fair Trade Commission.

3. Latvia: The primary goal of this measure is not to identify gender pay gaps, but rather for budgetary purposes. The system is used by The State Chancellery, in implementing the State policy in the field of remuneration of employees in the public sector, and the Ministry of Finance, in implementing the State policy in the field of the development of the State budget. More specifically the data are used to: 1) collect systematically and update data regarding the remuneration of officials (employees), as well as analyse the requests for financing and utilisation for remuneration; 2) planning and calculating the necessary financing by designing the draft State budget for the current year and drafting legislation regarding remuneration; and 3) identify and control the current situation regarding posts and the remuneration of officials (employees). See more at https://likumi.lv/ta/id/295098-noteikumi-par-valsts-tiesas-parvaldes-iestazu-un-citu-valsts-un-pasvaldibu-instituciju-amatpersonu-darbinieku-atlidzibas-un-personu-uzskaites-sistemu?&search=on.

4. In Norway, private enterprises with fewer than 50 employees also have an obligation to work for equality in their pay policy – even if they do not have an obligation to conduct a survey or report.

5. More information on Switzerland’s sunset clause here: https://www.bj.admin.ch/ejpd/fr/home/actualite/news/2019/2019-08-21.html.

Source: Updated from OECD (2023[1]), based on 2025 OECD Pay Transparency Questionnaire.

References

[1] OECD (2023), Reporting Gender Pay Gaps in OECD Countries: Guidance for Pay Transparency Implementation, Monitoring and Reform, Gender Equality at Work, OECD Publishing, Paris, https://doi.org/10.1787/ea13aa68-en.