This chapter presents a stocktaking of pay transparency measures across OECD countries, focussing on pay gap reporting, pay auditing and pre‑employment salary transparency measures. It begins by providing an overview of pay gap reporting and pay auditing systems across OECD countries and then presents a more detailed overview of reporting and auditing systems, focussing on worker coverage and required content of reporting; pay auditing requirements; communication and oversight; and use of digital tools and data to simplify reporting and reduce administrative burden for employers. It concludes by providing an overview of pre‑employment salary transparency measures, focussing on salary transparency mandates in job advertisements, requirements related to gender-neutrality in job advertisements, and prohibitions for employers on requesting jobseekers’ salary history.
Pay Transparency in Progress
Abstract
Gender pay gap reporting is set to become the norm across OECD countries. By the end of 2026, 84% of OECD countries (32 out of 38) are expected to mandate gender pay gap reporting by private sector employers at the national level, with growth driven by the EU Pay Transparency Directive. Currently 55% of OECD countries (21 of 38) mandate pay gap reporting by private sector employers.
The share of workers covered by pay gap reporting is growing, but remains patchy. Of the nine OECD countries that provided data, estimated coverage of reporting requirements ranges from around 4.4% of workers in the private sector in Canada – those in federally-regulated jobs – to 68% in Belgium. Only two OECD countries – Portugal and Spain – require all private sector employers to conduct pay gap reporting and document their work.
Disaggregation of pay information by job category is a common requirement (15 out of 21 countries with private sector pay gap reporting) but reporting categories do not always enable identification of pay gaps for equal work, or work of equal value.
Around half of OECD countries with mandatory private sector pay gap reporting (10 out of 21 countries) have pay auditing requirements that require employers to analyse and/or follow-up on gender pay inequalities. Requirements vary considerably across countries, with implications for efficacy.
Greater transparency of pay gap information can support efficacy, and 12 OECD countries now require some form of public disclosure of pay gap information by private sector employers. This includes Australia, Canada, France, Iceland, Israel, Japan, Korea, Lithuania, Norway, Portugal, Spain and the United Kingdom.
Compliance monitoring is common though in some cases limited. Approaches vary: 19 out of 21 OECD countries with mandatory private sector pay gap reporting provided detail on oversight approaches, with 10 adopting a “proactive” oversight approach, 6 adopting a “reactive” approach, and 3 reporting no monitoring.
Smart use of digital tools and administrative data can drive efficiency and accountability in pay transparency systems. Several OECD countries provide online reporting portals which facilitate public disclosure, while three countries – Denmark, Lithuania and Portugal – use administrative data to calculate gender pay gap information on behalf of employers, reducing compliance burden for employers.
Currently five OECD countries require private sector employers to include starting salary information in job advertisements. Evidence on effectiveness remains limited, and further evaluations are needed.
While job evaluation provides the basis to ensure that pay structures are based on gender-neutral, objective criteria, gender pay gap reporting can help to identify pay inequalities between men and women performing the same work or work of equal value. Where accompanied by action requirements, reporting can also help to unsure that employers act on unjustified pay inequalities – placing the onus of identifying and remediating such inequalities on employers, rather than workers.
This chapter provides an updated stocktaking of pay transparency measures across the OECD as of July/August 2025, focussing on gender pay gap reporting and pay auditing in the private sector, and salary transparency prior to employment. The information updates and extends OECD’s pay gap reporting database, as set out in the 2023 report Reporting Gender Pay Gaps in OECD Countries (OECD, 2023[1]) and the 2021 report Pay Transparency Tools to Close the Gender Wage Gap (OECD, 2021[2]). The chapter also provides new data on country efforts to simplify pay gap reporting through the use of administrative data and digital tools; efforts to ensure compliance with reporting requirements; and on pre‑employment salary transparency measures.
This report is written in a period of significant transition: most OECD countries report forthcoming changes to their pay transparency requirements, meaning that changes to the information presented in this chapter can be expected – particularly as EU OECD countries continue work to transpose the EU Pay Transparency Directive. Further follow-up, evaluation and analysis of these reforms and “what works” is warranted in this rapidly evolving policy space, as countries adopt varying approaches to achieve common goals.
As of July/August 2025, over half of OECD countries (21 of 38) require designated private sector employers to report on gender pay gaps (Figure 3.1). Affected employers must provide pre‑defined gender-disaggregated pay information to at least some stakeholders, such as workers, workers’ representatives, the government, and/or the public. Countries with such reporting requirements include Australia, Austria, Belgium, Canada,1 Chile,2 Denmark, Finland, France,3 Iceland, Ireland, Israel, Italy, Japan, Korea, Lithuania, Norway, Portugal, Spain, Sweden, Switzerland and the United Kingdom. This represents no change from the OECD’s last stocktaking report in 2023.
Distribution of counties by the presence of national-level regulations requiring private sector pay reporting, pay auditing, or related measures, OECD countries, July/August 2025
Note: Chart shows the distribution of national-level private sector pay reporting measures across OECD countries. Ten countries in which companies meeting defined criteria (e.g. firm size) are required to carry out regular gender pay audits and report gender-disaggregated pay gaps: Canada (federally regulated employers), Finland, France, Iceland, Ireland, Norway, Portugal, Spain, Sweden and Switzerland. Eleven countries in which companies meeting defined criteria are required regularly to report gender-disaggregated pay information without a broader audit: Australia, Austria, Belgium, Chile (the financial sector), Denmark, Israel, Italy, Japan, Korea, Lithuania and the United Kingdom. Countries in which all companies meeting defined criteria are required to report only gender-disaggregated data on workforce characteristics but not gender pay gap data are Colombia, Germany, Luxembourg, the Netherlands, Slovenia and the United States. Countries in which an ad hoc selection of companies are required to undergo gender pay audits as part of a targeted labour inspection (non-exhaustive list) include Costa Rica, Czechia, Greece and Türkiye. Some countries have subnational gender pay gap reporting policies in place.
Source: Updated from (OECD, 2023[1]), Reporting Gender Pay Gaps in OECD Countries: Guidance for Pay Transparency Implementation, Monitoring and Reform, based on the 2025 and 2022 OECD Pay Transparency Questionnaires, and EEOC (2025[3]), “Message from EEOC Acting Chair Lucas about Opening of 2024 EEO-1 Component 1 Data Collection”.
While the fundamental principles of reporting are similar, pay gap reporting requirements continue to vary significantly across OECD countries, including as to their:
Coverage – which firms are required to report and for which workers (see section 3.2);
Content – what information employers are required to report (see section 3.3);
Pay auditing requirements – whether and how employers are required to analyse and address gender pay inequalities (see section 3.4);
Communication requirements – how and to whom the pay information must be provided, and whether it must be provided proactively or upon request (see section 3.5); and
Oversight and enforcement approaches – the steps taken by countries to ensure compliance with the requirements (see section 3.6).
These design features have considerable implications for the reach and efficacy of pay gap reporting requirements, and cross-country approaches are elaborated in further detail below.
While pay gap reporting and pay auditing are increasingly popular pay transparency tools, not all OECD countries have yet adopted these comprehensive measures. Some have introduced related reporting requirements that promote gender equality in the workplace but do not facilitate full pay transparency. Others have only partial or ad hoc approaches to pay or gender-related reporting.
As of July/August 2025, six OECD countries required affected private sector employers to report only gender-disaggregated non-pay information, e.g. gender gaps in employee numbers, or in high-level positions (Colombia, Germany, Luxembourg, the Netherlands, Slovenia and the United States).
In four OECD countries (Costa Rica, Czechia, Greece and Türkiye) private sector employers are not systematically required to report on gender pay or non-pay information. Instead, these countries have a more ad hoc approach to pay gap reporting: some employers may be required to provide pay data in specific circumstances, for example during a labour inspection process.
Looking ahead, pay gap reporting is set to become the norm across OECD countries. The EU Pay Transparency Directive is driving a significant expansion in pay gap reporting in the EU – and by extension, in the OECD – as EU countries work to implement mandatory pay gap reporting that meets the Directive’s requirements. Taking into account possible delays in meeting the June 2026 deadline for transposition, by end 2026 it is expected that over three‑quarters of OECD countries (32 out of 38) will mandate such reporting for (at least some) private sector employers (Figure 3.2). In addition to the 21 OECD countries that already have such requirements, this would newly include Czechia, Estonia, Germany, Greece, Hungary, Latvia, Luxembourg, the Netherlands, Poland, the Slovak Republic and Slovenia. Many EU OECD countries with existing pay gap reporting will also need to broaden or adapt their reporting systems to meet the Directive’s requirements (see 1.2).
Distribution of countries by the presence of regulations requiring private sector gender pay gap reporting at the national level, OECD countries, expected by end 2026
Note: Assumes that all EU OECD countries that do not currently have mandatory gender pay gap reporting in the private sector implement such a requirement in line with the EU Pay Transparency Directive by end 2026, considering possible delays beyond the June 2026 deadline for transposition.
Source: 2025 and 2022 OECD Gender Pay Transparency Questionnaires; supplemented by desk research.
The Directive is also expected to drive a similar expansion in pay auditing requirements across OECD countries. Unlike pay gap reporting – which focusses on disclosing gender-disaggregated pay data – equal pay audits require employers to assess and/or act on pay information by conducting more detailed analyses of pay and/or non-pay information, typically to identify the extent and causes of gender pay inequalities, and often to develop action plans to remediate any unjustified pay inequalities.
Currently, 10 out of 21 OECD countries with mandatory private sector pay gap reporting also require equal pay auditing (Canada, Finland, France, Iceland, Ireland, Norway, Portugal, Spain, Sweden and Switzerland). By end 2026, most OECD countries (26 out of 38) are expected to have mandatory equal pay auditing processes alongside private sector pay gap reporting requirements, as EU OECD countries work to transpose the Directive’s provisions on equal pay auditing, or “joint pay assessments” in EU parlance (see Box 1.2). In addition to the countries that already have such requirements, this would newly include Austria, Belgium, Czechia, Denmark, Estonia, Germany, Greece, Hungary, Italy, Latvia, Lithuania, Luxembourg, the Netherlands, Poland, the Slovak Republic and Slovenia.
Coverage of gender pay gap reporting schemes varies considerably across countries, mainly regarding the criteria that determine which firms are required to report. This most commonly relates to firm size, but can also include other criteria such as firm sector.
3.2.1. Firm size thresholds
Reporting requirements generally target larger firms in the private sector, meaning that smaller firms are often exempt. Portugal4 and Spain are the only countries where all private sector employers are required to conduct and document pay gap reporting (see Annex C for a summary of OECD countries’ pay reporting rules, including as to firm size cut-offs and inclusion criteria, and Chapter 4 for case studies on pay transparency in Portugal and Spain). In Sweden there is also no minimum firm size requirement but only employers with more than ten employees are required to document their work, making it difficult to verify compliance among smaller employers.
Elsewhere, minimum firm size thresholds vary widely, from 10 workers (in Canada, for employers covered by the Pay Equity Act,5 and Sweden) to 518 employees (in Israel). The most common thresholds cluster around 50, 100, or 250 employees, with some countries using different thresholds for different aspects of reporting.
A handful of countries have expanded coverage of pay gap reporting requirements in recent years, as some countries have lowered firm size reporting thresholds or gradually phased in reporting requirements. In Ireland, pay gap reporting obligations were gradually expanded to cover private sector employers with at least 50 employees in 2025 – down from 250 in 2022 – as part of a gradual roll-out of the requirements. Japan has similarly extended coverage of its pay gap reporting requirements, from companies with 301 or more workers to employers with 101 or more workers. In Australia, coverage has been expanded beyond the private sector: reporting to the Workplace Gender Equality Agency (WGEA) became mandatory for public sector employers from 2023 (covering the 2022 reporting period), with requirements for public and private sector employers broadly the same.6 France’s public sector requirements were expanded in 2023, with new requirements rolled out in stages: state ministries reported first on 2022 data, followed by local government and, most recently, hospital and medico-social organisations publishing results in 2025.
Expansions in coverage are anticipated in future, too. Austria will need to lower its firm size threshold from 150 to meet the 100‑employee‑standard set in the EU Pay Transparency Directive, for example, though the Directive allows until 2031 to implement mandatory reporting for employers with 100‑149 workers. Israel has also introduced draft legislation proposing to apply pay gap reporting obligations to 200 or more employees, a considerable expansion from the current threshold of 518 or more employees.
More exceptionally in New Zealand, individual agency-level reporting requirements have been withdrawn: while public service agencies were required to publish their own agency-level pay gap data between 2019 and 2024, since 2025 this has no longer been mandatory. Agencies remain strongly encouraged by the Public Service Commission to continue doing so, and the Public Service Commission continues to collect pay and representation data from all agencies and to calculate and publish pay gaps by gender and ethnicity at an aggregate system (but not agency) level.
3.2.2. Worker inclusion rules
There remains considerable variation across countries in the criteria used to determine whether a worker “counts” toward the employee headcount for meeting the minimum size threshold for reporting. Key variation includes:
Which employees are counted – Many countries exclude temporary workers, independent contractors, and/or indirectly employed workers from headcount calculations. In some countries, part-time workers are counted with reduced weight (for example, in Belgium, workers employed at less than 75% of full-time hours count as 0.5 employees for headcount purposes).
When and where workers are counted – Reference dates to determine company size vary across countries. Some use a specific calendar date (such as year-end), others use the end of the fiscal year, and still others allow employers some flexibility in choosing a snapshot date. Geographic considerations also vary: countries differ in whether workers across all sites or subsidiaries are aggregated when calculating firm size, and how to count employees working across borders.
The workers whose pay information must be included in pay gap reporting tend to be the same workers that are included when determining headcounts, though there are some minor differences. For example, in Belgium, the threshold calculation (50 employees) is calculated in accordance with social elections regulations every four years, as an average, at the level of the technical operating unit. However, employers must report on employees within their legal entity over the two preceding calendar years (the technical operating unit and legal entity are generally the same, though there can be differences). Additionally, temporary workers are counted to some extent in determining the company’s headcount, but their wage data are not included in the company’s wage report as they are considered an employee of the temporary worker agency.
Some countries (e.g. Belgium, France, Denmark and New Zealand) exclude reporting for specific job categories or work functions where there are too few workers of one gender to calculate robust statistics. For instance, in Belgium job categories with fewer than three workers need not be reported on; while Denmark requires at least 10 workers of each gender per work function.
3.2.3. Other criteria for determining eligibility
In some countries, only a subset of private sector companies are required to report. In Canada, for example, reporting requirements apply only to federally regulated entities. In Chile, only entities supervised by the Financial Market Commission must report.
3.2.4. Reporting frequency
Eligible private sector firms are typically required to conduct gender pay reporting annually or biennially. About half of countries with reporting requirements in the private sector mandate annual reporting, while the other half require reporting every two years. The only exceptions in the private sector are Iceland and Switzerland, where employers are required to report every three or four years, respectively (obligations in Switzerland depend on the results of employers’ first pay reporting, see endnote7). Latvia requires monthly reporting, though this applies only to the public sector and serves primarily budgetary purposes rather than pay gap transparency. In some countries, such as Canada and Spain, there is a distinction between the frequency of basic pay reporting (which may be annual) and more comprehensive equal pay audits (which may be required less frequently, such as every five years in Canada or according to company equality plan schedules in Spain).
3.2.5. Coverage gaps persist
Differing inclusion rules result in considerable variation in coverage across countries as to the number of private sector employers required to conduct gender pay gap reporting, and the number of workers that have important pay information available to them which could help them to advocate for equal pay. The exclusion of small and medium-sized enterprises from reporting requirements means that a substantial share of employees remains outside of the scope of pay transparency measures.
While many OECD countries are not able to provide reliable estimates on the number of private sector employees covered by pay gap reporting requirements,8 available data point to significant variation across countries, and considerable gaps in coverage. Nine OECD countries provided estimates of the share of workers covered by private sector pay gap reporting requirements, requested as part of the OECD’s 2025 Pay Transparency Questionnaire. In the countries where figures were provided, estimated coverage ranges from 4.4% in Canada – those in federally-regulated jobs – to 68% in Belgium (Figure 3.3). Only two OECD countries – Portugal9 and Spain require all private sector employers to conduct and document pay gap reporting, implying full or near-full coverage.
Estimated share of workers in the private sector covered by mandatory gender pay gap reporting requirements, as a percentage of all workers in private sector companies, 2024 or nearest year
Notes: Estimates supplied by countries; see data sources and methodological notes below. Referent years vary by country: data for Australia, Canada, Chile and the United Kingdom refer to 2024; Belgium and Finland refer to 2023; Italy and Norway refer to 2022; Japan refers to 2021.
Australia: Data supplied by the Workplace Gender Equality Agency (WGEA), which received data covering 5 169 129 employees for the 2023‑2024 reporting period from 12 938 employing Australian Business Numbers (ABNs). The employee denominator is derived from the Australian Bureau of Statistics (2024[4]), which does not include a specific count for private sector employees but does include the total number of employed people (14 692 400). The employee denominator is derived from the Australian Bureau of Statistics (2024[4]), which does not include a specific count for private sector employees but does include the total number of employed people (14 692 400). The ABS public sector employment data (2024[5])(2 517 900 public sector employees) was used to derive the private sector estimate.
Belgium: Figures relate to employers that initiated the social election procedure at the end of 2023 for the establishment of a social consultation body at the level of well-being, i.e. companies with at least 50 employees (averaged over a reference period of four quarters). These companies largely correspond to those subject to Belgium’s gender pay gap reporting obligations, which also apply from the 50‑employee threshold. However, there may be minor differences in coverage because the workers for whom pay information must be calculated differ somewhat to those used to establish eligibility to hold social elections (the threshold calculation (50 employees) is calculated in accordance with social elections regulations every four years, as an average, at the level of the technical operating unit. However, employers must report on employees within their legal entity over the two preceding calendar years. Technical operating units generally correspond to legal entities, but there can be differences.
Canada: Data only represents employees covered by federal pay gap reporting measures under the Employment Equity Act, based on the Employment Equity Act: Annual Report 2024 (2024[6]), (data reported by employers for the 2023 calendar year). The employee denominator is taken from the “Key Small Business Statistics 2024”, (Statistics Canada, 2023[7]). Definitions of private‑sector employers differ across these data sources and percentages should be interpreted with caution.
Chile: The numerator is based on the “Sexto Reporte de Indicadores de Género en las Empresas en Chile 2024”, which covers enterprises that report gender-related information to the Comisión para el Mercado Financiero (CMF) under NCG 386 and NCG 461. The denominators are constructed using publicly available administrative data from the Servicio de Impuestos Internos (SII), specifically the Estadísticas de Empresa, which provide the total number of private sector enterprises and the total number of dependent workers reported for the year 2024.
Finland: Based on Statistics Finland (2026[8]).
Italy: Based on National Institute for Statistics – Statistical Yearbook 2024.
Japan: Data are based on the 2021 Economic Census for Business Activity, covering all industries except government services. Enterprise size is classified according to the number of regular employees at the enterprise level (including regular employees both in Japan and overseas). Although publication of the gender wage gap is mandatory for employers with 301 or more regularly employed workers, for the purpose of this figure the estimates were calculated for enterprises with 300 or more regularly employed workers, which is the category used in the abovementioned census.
Norway*: Private‑sector enterprises with more than 50 employees are required to report gender pay gaps annually, while smaller enterprises with 20‑50 employees must report upon request from employer or employee representatives, in line with the Equality and Anti-Discrimination Act (Section 26a and Section 26, second paragraph). This means the mandated reach covers all employers with 50+ employees, and the additional potential reach includes all employers with 20‑50 employees who may be required to report if a request is made. Taken together, an estimated 68.75% of private‑sector workers could fall under these reporting obligations. Based on Statistics Norway (2023[9]).
United Kingdom: Figures are calculated based on information from the Office for National Statistics (2024[10]).
Source: 2025 OECD Pay Transparency Questionnaire.
While all countries with mandatory private sector pay gap reporting require affected companies to produce some form of gender-disaggregated pay information, requirements vary considerably in scope and detail – ranging from simple, company-wide statistics to detailed breakdowns by worker characteristics and non-pay metrics.
3.3.1. What are employers required to report?
When it comes to what information needs to be provided, most OECD countries require affected private sector employers to report the overall gender pay gap (gender gaps in mean or median pay between men and women, in eight countries) or mean or median pay for men and women separately (in another eight countries). In other countries the pay information required to be reported is either not specified, or employers are required to collect data based on employees’ individual salaries. When it comes to pay information, Korea and the United Kingdom are the only countries that require affected employers to report only a top-line, company-wide gender pay statistic (OECD, 2023[1]) (see Annex D for a summary of the pay information that affected companies are required to report).
Affected companies are also commonly required to disaggregate pay information for different groups of workers. Private sector employers are commonly required to disaggregate pay information by job categories (15 out of 21 countries), however the job categories used vary across countries (and in some cases within countries, as employers can use the job categories in the job classification systems in use in their company). Most countries require or recommend that companies use a pre‑defined job classification system defined at the national level, in collective agreements, or defined by companies (see Annex E).
The types of job categories used in reporting affects the comparability of jobs within and across different groups of workers, and therefore how easy it is to identify gender pay gaps for equal work, and work of equal value. When job classifications or occupational groups are sufficiently granular and consistently defined, they allow employers to compare (pay gaps for) not only workers performing the same job, but also different jobs that require comparable skill, effort, responsibility and working conditions. This distinction is important for identifying gender pay gaps linked to occupational segregation, where women and men tend to work in different roles that may be equivalent in value, but have historically been valued (and rewarded) differently. Yet, existing approaches do not always enable comparisons of pay gaps for equal work, and – particularly – work of equal value: some countries do not require reporting by sufficiently granular job categories to facilitate such comparison, while in others requirements to report by job function do not easily facilitate comparison of pay gaps for work of equal value, where performed in different functions (see country case studies in Chapter 4, and a broader discussion on job evaluation and classification in Chapter 2). The EU Pay Transparency Directive may help to drive changes in this regard, as it requires employers to report on gender pay gaps for categories of workers performing equal work, or work of equal value.
Beyond requirements for employers to disaggregate pay information by job category, most countries also or alternatively require affected private sector employers to disaggregate pay information for specific groups of workers, such as by level of seniority (6 out of 21 countries), education and/or qualification (4 out of 21 countries), and/or by age (2 out of 2 countries) (see Annex D). This type of disaggregation can help to provide a more comprehensive understanding of pay gaps within organisations, and their drivers. Only two countries currently require pay information to be disaggregated by race/ethnicity: Canada, for companies required to report under the Employment Equity Act, and Belgium. The United Kingdom has signalled its intention to introduce mandatory ethnicity and disability pay reporting in the coming years.
Alongside (or sometimes separate to) gender pay reporting requirements, some countries also mandate reporting on gender-disaggregated “non-pay” information, providing insights on gender gaps in factors such as employee numbers, contract types or promotion rates. Currently, private sector employers in at least 24 OECD countries are required to report non-pay statistics by gender. As of July/August 2025, six OECD countries – Colombia, Germany, Luxembourg, the Netherlands, Slovenia and the United States – require private sector companies to report such non-pay information, but not pay gap information. The other 18 countries require the reporting of non-pay information alongside other pay gap reporting requirements, either as part of pay gap reporting requirements or as part of another measure. This includes Austria, Australia, Belgium, Canada, Chile, Denmark, Finland, France, Ireland, Israel, Italy, Japan, Korea, Lithuania, Norway, Portugal, Spain and Switzerland. Non-pay reporting requirements typically include a requirement to report gender gaps in the number of employees overall (in 16 countries) often disaggregated by seniority/leadership (14), by job category (12), by contract type (11), or by salary class (8). Requirements to report gender differences in hiring, promotion and termination rates are also common (see Figure 3.4).
Number of countries requiring affected private sector firms to report the following forms of gender-disaggregated non-pay information (out of 24 countries)
Note: Responses indicate no changes to the required content of non-pay information since last reported in 2022 (OECD, 2023[1]). Information is current as of July/August 2025, when the bulk of data collection took place.
Source: Updated from OECD (2023[1]), Reporting Gender Pay Gaps in OECD Countries: Guidance for Pay Transparency Implementation, Monitoring and Reform, based on 2025 OECD Pay Transparency Questionnaire.
3.3.2. Some countries are expanding the breadth of reporting
As outlined in Chapter 1, there is some momentum toward expanding the breadth of pay and non-pay information that affected employers are required to report, at least in a handful of countries. At least three OECD countries – Australia, Belgium and Japan – have recently implemented some expansions in the breadth of reporting requirements, while in other countries such changes are anticipated. In Australia, reporting of CEO remuneration has become mandatory for public and private sector organisations (for the 2023‑2024 reporting period in the private sector and the 2024 reporting period in the public sector respectively). Employers are now also required to report on wages by location (by workers’ primary workplace location10), and to provide additional information on their efforts to prevent and respond to sexual harassment in the workplace. Collection of age‑disaggregated data has been paused but is due to resume in 2026. In Belgium, since 2023 legislation on social elections has required the disclosure of gender statistics not only for employee representative (candidates nominated and elected), but also for employer representatives (appointed by the employer) (in Belgium, specified employers with at least 50 employees are required to hold social elections every four years to establish and renew consultation bodies within the company). In Japan, pay gap reporting requirements were expanded in 2025 to require eligible employers to report on the proportion of women in managerial positions, in addition to existing reporting requirements.
The scope of the pay and non-pay information that employers are required to report looks set to expand in the coming years. The United Kingdom reports plans to introduce mandatory ethnicity and disability reporting. Expansions to reporting requirements in the EU also seem likely as countries transpose the EU Pay Transparency Directive. Variation could be expected across countries given existing variation in reporting systems, and that some may use the requirement to transpose the Directive as a window of opportunity to refine and expand their pay reporting systems, and/or to go “over and above” the minimum criteria set out in the Directive. The Belgian region of Fédération Wallonie‑Bruxelles, for example, passed legislation in 2024 making it mandatory for affected organisations to include in their annual pay gap report an assessment of pay progression for workers that take maternity, childbirth, adoption, parental or other leave in the context of family responsibilities, going beyond the minimum requirements set out in the Directive.11
Nearly half of OECD countries with private sector pay reporting rules have embedded reporting within or alongside equal pay auditing processes (10 out of 21), typically requiring companies to assess and/or follow-up on gender pay inequalities. This represents no change from the OECD’s last stocktaking in 2023, though a significant expansion in pay auditing is anticipated as EU countries work to transpose the EU Pay Transparency Directive. As outlined in Chapter 1, by end 2026 it is expected that 26 out of 38 OECD countries will have pay auditing requirements for private sector organisations.
As of July/August 2025, countries requiring equal pay audits by private sector companies include Canada, Finland, France, Iceland, Ireland, Norway, Portugal, Spain, Sweden and Switzerland, with requirements varying considerably across countries. Equal pay audits represent a more comprehensive pay transparency tool that goes beyond simple pay gap reporting, offering a means to analyse broader gender inequalities within firms, understand their underlying causes, and (often) requiring some follow-up action from employers. Typically, equal pay audits involve analysing the representation of women and men in different positions, assessing job evaluation and classification systems, and gathering detailed information on pay and gender pay differentials. An effective audit should not only identify gender pay gaps but also examine the reasons behind them, facilitating the development of targeted actions to address pay inequalities.
3.4.1. When do companies need to conduct a pay audit?
Pay auditing requirements vary considerably across countries, both in terms of when the obligation arises, and what employer are required to do. In some countries audits are mandatory for all employers, while in others the obligation arises when substantial gender pay gaps are detected through pay gap reporting. For example, Spain requires all private sector employers with 50 or more employees to conduct a pay audit as part of broader requirements to develop an equality plan, while in Portugal the requirement to conduct a pay audit arises when private sector employers with 50 or more employees have unjustified pay gaps >5% (see the case studies on pay transparency in Portugal and Spain in Chapter 4 for more information on these requirements). Some convergence is expected across EU OECD countries with implementation of the EU Pay Transparency Directive, which requires employers who identify unjustified pay inequalities >5% to carry out a joint pay assessment – a form of pay audit – if those inequalities are not remedied within six months (see Box 1.2).
The “trigger” for the requirement to conduct a pay audit – and/or to take action based on the results of that audit – varies across countries. In a handful of countries, all affected employers falling under reporting obligations are required to conduct audits and (often) to take action regardless of whether inequalities are detected. Sweden requires all employers in the public and private sector to conduct an annual pay audit (referred to in Sweden as an “equal pay survey”) assessing work of equivalent value, amongst other things, and to pursue continuous prevention and promotion work, including investigating risks of discrimination, analysing causes, and taking reasonable measures. In Finland, all employers must develop gender equality plans that assess the workplace situation, implement measures to promote equality, and review previous implementations. Similarly, Norway requires all employers to implement measures to counteract discrimination and promote equality, though formal action plans are not mandated.
Other countries trigger specific audits or remedial actions only when pay gap reporting reveals inequalities or falls below certain thresholds. In France, employers must set improvement targets when their Professional Equality Index score falls below 85 points out of 100, and must define and publish corrective measures when the score falls below 75 points. Companies scoring below 75 have three years to reach this threshold or face financial penalties. Canada requires compensation increases when any pay difference between predominantly male and female job classes of equal value is detected under the Pay Equity Act with increases due within three years (or phased over three to five years if they exceed 1% of annual payroll). Iceland, Ireland and Portugal similarly require action plans or explanatory reports specifically when gender gaps are identified. Spain requires justification when pay gaps of 25% or more are detected, while Korea mandates improvement plans when employers’ female worker or female manager ratios fall below 70% of sector averages.
Many countries also establish specific timelines and monitoring provisions for action to address pay gaps identified through pay auditing. For example, under Canada’s Pay Equity Act, when pay differences between predominantly male and female job classes are detected, employers must increase compensation for the predominantly female job class within three years (or up to 5 if these increases exceed 1% of the employer’s annual payroll). In Portugal, when the Labour Inspectorate detects pay differences through its analysis of mandatory pay reporting, employers must submit an evaluation plan – justifying gaps using objective criteria and proposing corrective measure where they cannot – within 120 working days. Employers then have 12 months to implement the plan before reporting back to the Labour Inspectorate on the results.
3.4.2. What are companies required to do as part of the pay audit?
Countries vary considerably in what they require from firms conducting equal pay audits. Some, like Spain and France, provide relatively explicit instructions. Spanish employers must describe job classification systems, analyse potential direct and indirect gender discrimination, detect pay differences and identify their causes, while in France employers are required to calculate specified gender pay indicators and take follow-up action where scores fall below an “allowable” equality threshold (See Chapter 4 for more information on Spain and France’s requirements). In Nordic countries, guidance tends to be more general, though regulations demand in-depth understanding of gender differences within organisations.
Most countries requiring private sector equal pay audits require analysis of equal pay for work of equal value through gender-neutral job evaluations and/or classifications. This includes Canada, Finland, Iceland, Norway, Portugal, Spain, Sweden and Switzerland – enabled there through the Logib tool. This approach recognises that closing gender pay gaps requires addressing the undervaluation of female‑dominated jobs. Several countries also mandate statistical analysis of gender pay gaps, with Canada and Switzerland providing detailed methodological guidance or tools such as Switzerland’s Logib (see Section 3.7 for more information on digital tools and Box 2.4 for more details on Logib).
Countries with pay auditing requirements tend to have embedded some monitoring or oversight of such obligations, often involving explicit follow up mechanisms as well as dedicated government entities such as labour inspectorates, gender equality agencies, or ombudsmen. Some involve independent bodies: certified external auditors are required to conduct inspections in Iceland and Switzerland, while Finland, Norway and Sweden mandate that analysis be conducted in co‑operation with employees and their representatives.
Effective pay transparency depends not only on what information employers must report, but also on how reporting requirements are communicated to employers, how results are shared with stakeholders, and whether workers understand their rights to access pay information. Evaluations across countries show that public transparency appears to make pay gap reporting more effective across countries, and that weak communication to employers can constrain effectiveness (Frey and Alajääskö, 2023[11]): employer awareness of requirements is often limited, compliance rates vary widely, and workers rarely exercise their rights to request pay information.
3.5.1. Proactive outreach can improve employer awareness
How reporting requirements are communicated to employers varies across countries. Most countries expect employers to familiarise themselves with legal requirements through government websites, legal bulletins, or official gazettes. However, some countries – notably Australia, Canada and France – proactively communicate requirements and/or remind employers of their obligations by directly emailing employers or undertaking targeted outreach. Some countries, including Austria, Chile and Japan, produce information leaflets and brochures to support employer compliance. Japan’s approach also emphasises institutional support mechanisms: Prefectural Labour Bureaus provide consultation services to workers and corrective guidance to employers, while the Equal Opportunity Mediation Committee offers dispute resolution as an accessible alternative to court proceedings. In several countries, including Austria, Belgium and Finland, worker representatives have also played an important role in helping to communicate reporting requirements to employers.
Overall, employer awareness of reporting requirements is rarely measured systematically, making it difficult to assess the effectiveness of different communication strategies. Some national evaluations show that limited awareness remains a significant barrier, constraining the efficacy of different pay transparency measures (in Austria, Germany and Switzerland) (see Section 1.5).
3.5.2. Direct worker communication can facilitate action on pay inequities
Most OECD countries with private sector reporting requirements require employers to report at least some pay information directly to workers, though there is considerable variation in how and when they are required to do so. Currently, 16 out of 21 OECD countries with pay gap reporting requirements in the private sector require reporting directly to workers, including Australia, Austria, Belgium, Canada, Denmark, Finland, France, Iceland, Israel, Italy, Lithuania, Norway, Portugal, Spain, Sweden, and Switzerland). Depending on the country, employers a) are explicitly required to communicate specified pay information to workers, b) may notify workers that pay analysis has taken place, or c) are required to make the information available on request, rather than providing it proactively. For example, Australia requires all employers to provide gender equality reports to employees and to make specified pay information publicly available, while Finland requires audit results and updates to be actively shared with employees through various means such as workplace intranets or staff meetings. Switzerland requires written notification to employees within specific timeframes following audits, while others, like Italy and Spain, allow workers to request information rather than receiving it proactively.
Many countries also mandate that results be shared with worker representatives or works councils (13 out of 21: Australia, Austria, Belgium, Canada, Denmark, Finland, France, Iceland, Itay, Norway, Portugal, Spain and Sweden). In some countries, this serves as the primary channel through which individual employees access pay information – receiving it indirectly through their representatives rather than directly from employers. In Spain, employees can generally only access the information in company pay registries by requesting it from the legal representative of workers in their company; only in companies without worker representatives can they access pay registries directly, and view only percentage differences rather than absolute figures.
Mandatory reporting of gender pay gap reporting to equality or other state bodies is also a common requirement (currently in 11 out of 21 OECD countries with pay gap reporting requirements in the private sector: Australia, Canada, Chile, Denmark, France, Iceland, Israel, Italy, Lithuania, Portugal, and Sweden), though the specific agencies and reporting requirements vary considerably. In at least 5 of these 11 countries employers must report to specialised equality agencies, and in another 5 employers report to labour or regulatory bodies.
What information employers are required to communicate also varies across countries. For instance, in Norway employees must have an actual opportunity to compare their salary with the average at their level, though detailed breakdowns by different positions or groups are not required. In France, employer-level scores on the Professional Equality Index are made publicly available. At the organisational level, employers must make detailed results available to the social and economic committee (CSE) via the economic, social and environmental database (BDESE) before the meeting following publication of the Index. This information must include all calculable indicators, broken down by socio-professional category, hierarchical level or coefficient, or by the company’s job grading method, along with methodological information, including the methodology used to construct the sample for comparing remuneration, and any corrective measures envisaged or already implemented. Where certain indicators cannot be calculated, employers must still provide the CSE with those that can be calculated, along with an explanation of why the others could not be. The CSE must receive at minimum all information also transmitted to the Ministry of Labour. However, while detailed information on pay gaps is provided to the CSE and trade union delegates via the BDESE for their consultation role, French law does not require these representatives to share this information with individual employees or the general public.
The EU Pay Transparency Directive will likely help to increase clarity and consistency in the communication of pay transparency in EU countries, as it contains a specific requirement for public reporting of specified pay gap information, through a designated monitoring body (see Box 1.2).
3.5.3. Public disclosure can drive accountability and help reduce pay gaps
Available evidence on the effectiveness of pay gap reporting in the private sector suggests that active disclosure and public dissemination of pay gap information play a positive role in the effectiveness of pay transparency measures (see section 1.5) (OECD, 2023[1]; Frey and Alajääskö, 2023[11]; Eurofound, 2025[12]). Public reporting creates multiple accountability mechanisms: it empowers workers by reducing information asymmetries and enabling them to identify inequities and negotiate more effectively; it enables investors and customers to include gender equality considerations in their decisions; and it facilitates benchmarking across firms while enabling governments and researchers to track progress over time. Public disclosure also exposes employers to reputational scrutiny from workers, consumers, investors, the media and civil society, generating pressure to act – particularly for firms that are consumer-facing or competing for talent.
A growing number of OECD countries (12) now require some form of public disclosure of private sector pay gap information, recognising that transparency can help to promote accountability and change. This includes Australia, Canada, France, Iceland, Israel, Japan, Korea, Lithuania, Norway, Portugal, Spain, and the United Kingdom. However, the content, format, and accessibility of public disclosure vary considerably across countries.
Centralised reporting databases can facilitate public disclosure. Some countries have established central, public and searchable databases that enable the general public to access gender pay gap information for companies, often in a manner that enables them to compare pay gap across employers, sectors, and/or over time. Australia, for example, has recently begun public reporting of employer pay gap information. Following legislative changes in 2023, Australia’s Workplace Gender Equality Agency (WGEA) published gender pay gap information for affected private sector employers for the first time in 2024, with national, industry and employer-level data accessible and fully searchable in an online data explorer (see Figure 3.5). In addition to enabling the general public to view gender pay and non-pay information for specific employers, and actions to be taken as a result of gender pay gap analysis, the data explorer also enables users to view other information related to gender equality, such as available support measures (e.g. flexible work, parental leave, support for carers, and measures related to family and domestic violence). Data are published annually, and the WGEA also publishes a list of non-compliant employers on its website annually.
Central public databases are also in operation in other OECD countries, including in Canada, France, Korea, Lithuania and the United Kingdom. Since 2017, companies with 250 or more employees in the United Kingdom have been required to publish their gender pay gap figures annually on their own website and through a government database. This publicly accessible database facilitates straightforward comparison across employers and has generated significant media attention, with associated reputational incentives to address gender pay gaps. There is some evidence to suggest that the requirement for public disclosure has contributed to reductions in gender pay gaps among affected firms (see Chapter 1). Korea implemented elements of the United Kingdom’s public disclosure model, with affected employers required to make at least some gender pay gap results available to the general public.12 In France, companies’ Professional Equality Index (PEI) scores are made publicly available in an online database, where individual employers can be identified (see Chapter 4 for more information on pay gap reporting in France).
Snapshot from the Workplace Gender Equality Agency (WGEA) Employer Data Explorer showing workforce composition, gender pay gaps, and gender equality policies for the Australian private sector, 2024‑2025 reporting year
Source: Workplace Gender Equality Agency (WGEA), Employer Data Explorer, accessed 4 December 2025, https://www.wgea.gov.au/data-explorer.
Canada has a mixed approach to public transparency, highlighting that even within countries, different legislative frameworks can result in varying levels of public transparency. Under the Canadian Employment Equity Act, which applies to federally regulated private‑sector employers with 100 or more employees, pay-related data are published to the general public. However, under the Pay Equity Act, which requires employers to post their pay equity plan in an accessible manner for employees, the plans are not published to the general public (though they must be accessible to employees and are submitted to the Pay Equity Commissioner). In Japan, gender pay gaps are made publicly available on the website run by the MHLW including “Database on firms that promote women’s participation and advancement”.
Administrative data can also support public transparency. Lithuania takes a distinctive approach by leveraging existing administrative data systems to facilitate public transparency. The State Social Insurance System (SODRA) gathers salary information from employers and releases anonymised, aggregated data to the general public, providing transparency at both firm and sector levels. This system reduces reporting burden for individual employers while facilitating public accountability. Employee representatives can request more detailed average salary data by category and gender annually (provided there are more than two employees per job category), offering an additional layer of transparency for workers.
Effective oversight and enforcement are important mechanisms to help ensure compliance with reporting requirements. Recent OECD work on pay gap reporting set out a number of factors that can support compliance, including clear communication and simplification of reporting requirements; routine and risk-based monitoring; and focussing compliance efforts on companies most likely to be non-compliant (rather than blanket monitoring) (see OECD (2023[1]), Reporting Gender Pay Gaps in OECD Countries for further details on oversight and enforcement approaches). Random compliance checks, too, and more “reactive” approaches – e.g. having a government body available to respond to individual or groups of workers’ complaints – can help build understanding of overall compliance rates and identify non-compliance.
Smart use of data and digital tools can facilitate efficient compliance monitoring, too, potentially at relatively low cost. In France, for example, centralised reporting through a digital portal provides a data source for the Labour Inspectorate to identify companies that have not met their equality obligations, e.g. where they have failed to improve equality scores below “allowable” thresholds within required timeframes. Subject to available data, it could in principle also be relatively straightforward for oversight bodies to conduct automated or semi‑automated compliance checks using administrative data, for example comparing a list of organisations required to report (by firm size) to those that have reported, using a unique identifier such as company number.
3.6.1. Compliance monitoring is common across countries, but intensity varies
The OECD’s 2025 Pay Transparency Questionnaire sought to explore country approaches to oversight of gender pay gap reporting requirements.19 out of the 21 OECD countries with private sector pay gap reporting requirements responded to questions related to oversight, and responses highlight a diverse range of oversight approaches.
Results show that compliance monitoring is common. 16 out of the 19 OECD countries with private sector pay gap reporting requirements that responded to the 2025 Pay Transparency Questionnaire’s questions related to compliance report taking at least some action to monitor and/or enforce employer compliance with these obligations. This includes Australia, Belgium, Canada, France, Finland, Iceland, Israel, Italy, Japan, Korea, Lithuania, Norway, Portugal, Spain, Sweden and the United Kingdom (see Table 3.1).
An additional two countries with private sector pay gap reporting requirements – Austria and Switzerland – report monitoring public sector organisations’ compliance with their reporting obligations, but not private sector companies’. In Austria monitoring of public sector compliance is conducted by the competent division of the Federal Chancellery, with data on pay and tasks of employees available at divisional level. In Switzerland, oversight and enforcement are conducted in the context of public procurement and subsidies – including through pay equity audits and inspections – though broader enforcement of the Gender Equality Act analysis requirement outside of this context is lacking.13 Denmark reported that compliance with pay gap reporting obligations is not monitored, though in Denmark a government agency (Statistics Denmark) produces gender-segregated pay statistics for companies covered by regulations, meaning active governmental monitoring of compliance is less relevant.
Among countries that report monitoring private sector employers’ compliance with the requirements, approaches differ significantly: some report adopting a proactive approach, while others adopt a more reactive approach (see Table 3.1):14
Most OECD countries that report monitoring compliance with private sector companies’ obligations report taking a “proactive” approach’ to compliance (10 out of 16 countries), where a government body or agency takes active steps to check that companies have met their requirements – e.g. through routine monitoring and/or targeted assessment.
The other OECD countries with such requirements report a more “reactive” approach (6 out of 16 countries), meaning that an agency does not actively monitor compliance, but would investigate and/or enforce compliance if they became aware of an instance of possible non-compliance – typically if brought to their attention through complaints from workers, their representatives or the public. In this approach a greater deal of the burden of identifying possible non-compliance rests with workers. In countries where pay gap reporting information is not easily accessible, detecting non-compliance may therefore be particularly challenging.
Proactive approaches vary in intensity and focus
Across the OECD countries that report taking a proactive approach to monitoring compliance with private sector employers’ pay gap reporting obligations – Australia, Canada, France, Iceland, Japan, Korea, Lithuania, Portugal, Spain and the United Kingdom – there are significant differences in the oversight approaches adopted (see Table 3.1).
Some countries reporting undertaking regular or routine monitoring to verify whether affected companies have reported. In Australia, the Workplace Gender Equality Agency (WGEA) conducts routine and risk-based checks, drawing on data analysis and cross-referencing with other government sources. In the United Kingdom, the government maintains a list of employers believed to be in scope and uses it to identify possible non-compliance, e.g. companies that have not reported by the deadline; this information is passed to the Equality and Human Rights Commission (EHRC).
In some countries, monitoring focusses on whether the information submitted is complete and accurate. In Canada, Employment and Social Development Canada’s (ESDC) online portal – the Workplace Equity Information Management System (WEIMS) – automatically reviews and validates submissions. ESDC staff also conduct additional manual checks.
Other countries do not conduct routine compliance checks, but government bodies can perform proactive audits or inspections. In France, the Labour Inspectorate can carry out targeted inspections based on the information submitted by companies in the Professional Equality Index – for example, of companies scoring below 75 on the Gender Equality Index for four consecutive years.
Iceland takes a distinct approach through its Equal Pay Certification system, introduced in 2018. Companies must obtain certification from an accredited body confirming that their equal pay management system meets the requirements of the national Equal Pay Standard, which includes having a pay system which ensures equal pay for work of equal value (ÍST 85:2012).
Lithuania uses publicly available data (SODRA) that enable targeted enforcement by the State Labour Inspectorate. While there is no formal procedure or explicit criteria, the Inspectorate monitors the published wage data for patterns that suggest potential gender inequality. If wage differences of 10‑15% between men and women appear repeatedly across multiple companies in a particular sector, the Inspectorate may conduct co‑ordinated inspections of companies within that sector to investigate potential systemic pay discrimination.
Several countries also prioritise proactive compliance support, aiming to help prevent non-compliance by actively reminding employers of their obligations and supporting them to comply. Australia’s WGEA Compliance Strategy emphasises prevention, identification and response. Canada’s ESDC contacts employers well before reporting deadlines, and the United Kingdom has conducted periodic reviews to identify organisations that should be reporting under the regulations but have not yet done so, proactively contacting them to ensure awareness and provide compliance guidance.
Reactive approaches to oversight rely on complaints and emphasise guidance
Six OECD countries reported adopting a reactive approach to monitoring compliance with private sector employers’ obligations – Belgium, Finland, Israel, Italy, Norway and Sweden – meaning that authorities do not routinely check employer compliance, but would investigate and/or enforce when cases of possible non-compliance are brought to their attention.
Reactive approaches commonly rely on complaints/reports as triggers for investigation or enforcement action. In Belgium, the Social Law Enforcement Department intervenes in the event of a complaint related to non-compliance and can take enforcement action. Israel’s Equal Employment Opportunity Commission (EEOC) is authorised to require employers to provide data on the fulfilment of their obligations by decree, but does not conduct systematic, routine monitoring across all employers.
Some countries place particular emphasis on the role of workers and their representatives in identifying non-compliance. Italy reports that equality bodies and workers’ representatives can report non-compliant companies to labour inspectorates. The inspectorate gives non-compliant employers an additional 60‑day deadline; those that remain non-compliant are sanctioned and may be excluded from public benefits and procurement after 12 months.
Other countries pair reactive enforcement with a guidance and support-oriented approach. In Finland, the Ombudsman for Equality first seeks voluntary compliance through instructions and advice before escalating cases to the National Non-Discrimination and Equality Tribunal, which can impose fines. Norway and Sweden follow similar models: the respective equality bodies can assess employer reports, request improvements, and may refer cases to tribunals that can issue compliance orders or financial penalties. In Norway, the Ombud reviews both the existence and the quality of employer statements, and can make follow-up visits.
Note: A “proactive approach,” means that the agency takes active measures to check that companies have complied with the relevant requirements, for example by checking that companies who are obliged to conduct pay gap reporting have done so. A “reactive approach” means that the agency does not actively monitor compliance, but would investigate and/or enforce compliance if they became aware of an instance of possible non-compliance. Countries that apply both a “proactive” and “reactive” approach have been listed as applying a “proactive” approach. Note that not all countries who responded to the 2025 OECD Pay Transparency Questionnaire provided information in response to this question. Information is current as of July/August 2025, when the bulk of data collection took place.
1 Information for Canada relates to the Employment Equity Act (EEA) and Pay Equity Act (PEA).
2 In Korea, among workplaces subject to Affirmative Action, those that fail to meet the female employment standards are required to prepare and submit the “Affirmative Action Implementation Plan” in accordance with Attachment 4 of the Enforcement Regulations of the “Equal Employment Opportunity and Work-Family Balance Assistance Act.” They are subsequently also required to submit the “Report on the Outcome of Affirmative Action Implementation” in accordance with Attachment 6 of the Enforcement Regulations of the Act. Responsibility for supervising Affirmative Action compliance was transferred from the Ministry of Employment and Labor to the Ministry of Gender Equality and Family in October 2025.
3 In Norway, employers legally have an “active duty” to work actively and systematically to promote equality and prevent discrimination in the workplace, with a number of specific requirements.
4 In Portugal, companies are quired to submit a pay audit and evaluation plan where there are pay differences > 5% and companies are notified by the Authority for Working Conditions that they are required to submit an evaluation plan.
Source: 2025 OECD Pay Transparency Questionnaire, supplemented by country interviews; OECD (2023[1]), Reporting Gender Pay Gaps in OECD Countries: Guidance for Pay Transparency Implementation, Monitoring and Reform; Canada’s Workplace Gender Equality Agency (2025[13]), Compliance Strategy.
As outlined above, some countries focus monitoring efforts only in the public sector. Austria monitors compliance in the Federal public service, but not for private sector companies. Switzerland takes a slightly different approach: the Federal Office for Gender Equality (FOGE) carries out around 30 random annual checks to ensure that companies participating in federal public procurement comply with equal pay requirements. However, a recent evaluation of Switzerland’s private sector reporting shows that less than half of affected companies are complying with pay gap reporting requirements (Federal Office of Justice, 2025[14]).
3.6.2. The focus of compliance monitoring – what is monitored – varies across countries
Beyond the distinction between proactive and reactive approaches, countries also differ in what they monitor – whether oversight focusses on whether a report has been submitted, or extends for example to checking the quality of reporting, and/or whether employers are (where required) taking action on inequalities identified in the process of reporting.
In some countries, compliance monitoring focusses primarily on whether employers have submitted required information. In others, authorities also assess whether the information is of sufficient quality. In Norway, where reviews of equality statements are conducted, the Equality and Anti-Discrimination Ombud reviews both the existence and the content of employer equality statements. In other countries, oversight extends to ensuring that employers have met their pay auditing obligations to improve on pay equity. In France, compliance activity is tied to gender equality outcomes for companies with low equality scores (scoring below pre‑defined thresholds on the Professional Equality Index) rather than simply the filing of a report – although the share of companies required to take such actions is relatively low in practice (discussed in further detail in the pay transparency case study for France in Chapter 4).
Pay gap reporting is often facilitated through standardised reporting templates or forms which employers are required to complete. The development of these tools has typically involved multiple stakeholders, with different processes and levels of involvement across countries.
In most OECD countries with mandatory pay gap reporting, the reporting templates are specified in legislation or regulations. The process of developing them often involves consultation processes with social partners and employer organisations. Norway, for example, held public consultations when activity and reporting duties were strengthened under the Equality and Anti-Discrimination Act in 2020. Similarly, in countries such as Australia, Denmark, Iceland, and the United Kingdom, while reporting tools are defined in legislation, their development involved input from both employers and worker representatives to ensure the templates are practical to implement and effective in capturing meaningful pay gap information.
In some countries, social partners have played a more direct role in designing reporting frameworks. Austria involved social partners in defining aspects of its reporting requirements, while in Spain and Switzerland, social dialogue contributed to shaping the reporting tools. Employer organisations have also been involved in tool development or refinement in several countries, including Australia, Canada, Finland, Israel, Spain and the United Kingdom.
3.7.1. How are digital tools and data used to support reporting?
Governments are increasingly providing digital tools to help employers calculate and report pay gaps, reducing administrative burden and making compliance easier. Such approaches could be particularly beneficial for small businesses. Where implemented effectively, these tools also standardise data collection, enable effective monitoring, facilitate comparisons across employers, sectors and regions, and support public dissemination of results. Several countries provide online portals where employers can register, calculate, and/or submit pay data: Australia, Canada, France, Italy, Korea, Switzerland, and the United Kingdom offer comprehensive online portals. In Australia, Canada, and Switzerland, portals use individual employee‑level data submitted by employers to automatically calculate organisation-wide gender pay gaps and generate reports. Belgium and Spain provide downloadable reporting forms via government websites. Most countries that offer reporting through reporting portals (Australia, Canada, France, Italy, Switzerland, United Kingdom) mandate their use for submission and/or calculation.
At least two OECD countries have reported (planned) updates and improvements of their digital infrastructure. Italy has taken steps to simplify compliance and strengthen support: in June 2024, it replaced its 2022 Interministerial Decree on biennial gender reporting (for companies with 50+ employees) with a streamlined version featuring an updated online application with pre‑compilation and data retrieval functions, new guidelines, an online help platform, and expanded FAQs to assist companies with interpretation and practical issues.
Ireland announced in March 2025 the upcoming launch of an official centralised gender pay gap reporting portal that will host a publicly searchable database of employers’ gender pay gap reports, replacing the previous system where employers published reports on their own websites or made them available directly to employees. A voluntary pilot is currently underway, with mandatory reporting through the official system anticipated thereafter.
Some countries offer standalone calculation tools. Norway provides downloadable calculators for voluntary analysis. France offers both an anonymous calculation simulator and a declaration tool. Portugal provides the Gender Pay Gap Calculator (DSG) plus a Self-Assessment Survey on Equal Pay. Iceland offers unique job classification software called Embla, based on their Equal Pay Standard methodology.
Less common but valuable resources include e‑learning and training tools. France offers a two‑week online training (1.5 hours/week) covering the Professional Equality Index, scoring, related obligations, and gender equality resources. Sweden provides a three‑module training on collaboration, data collection and analysis, and documentation, with self-assessment features. In Israel, the Equal Employment Opportunity Commission has issued non-binding guidelines regarding the reporting process and a sample questionnaire.
Digital tools have many potential benefits. They ensure standardised frameworks for consistent data collection within and across firms, helping to facilitate compliance by simplifying administrative requirements and reducing “know-how” challenges, and supporting monitoring of reporting requirements by authorities. They also allow more streamlined public reporting and dissemination of results as well as national-level comparisons through standardised data formats (for example, across employers, sectors, and regions).
Indeed, a comprehensive evaluation (Hardoy, Schøne and Østbakken, 2024[15]) examining Norway’s pay transparency scheme notes that increased oversight or standardisation could improve usability, but also weaken the tool’s core strength, which is encouraging companies to conduct meaningful, context-specific analysis of their own pay equity challenges. Overly rigid reporting requirements could reduce the exercise to a compliance checklist, with companies mechanically filling in standardised forms rather than investigating the causes of pay gaps within their organisational contexts. In the Norwegian context, the report recommends transparency through a reporting portal rather than stricter methodological harmonisation.
3.7.2. Administrative data holds untapped potential to reduce administrative burden for employers
A particularly novel and promising approach is the use of administrative data to fully or partially calculate gender pay information, reducing or eliminating administrative burden for employers (OECD, 2023[1]). Governments can use existing administrative and survey data (tax records, social security contributions, employer-employee datasets) to calculate gender pay gaps for companies, eliminating the need for employers to perform calculations themselves. To enable this approach, governments need to link at least three pieces of information: individual’s earnings, their employer, and their gender (typically held by the employer). Ideally, the dataset would also include job category (to enable comparisons) and hours worked (to include part-time workers as required by regulations). A central agency (such as a tax authority or social security administration) could then conduct pay gap analyses for individual employers across an entire country using data already collected through administrative processes, removing the calculation burden for companies partially or entirely.
Currently three OECD countries – Denmark, Lithuania and Portugal – report using administrative data to partially or fully calculate gender pay gap information on behalf of private sector employers. In these countries, administrative data are used to fully calculate required pay information for affected employers. In Portugal, government authorities use employer-submitted administrative data – collected through an employment survey (the Quadros de Pessoal or “Single Report”) – to calculate gender pay gap information for employers (see Portugal’s case study in Chapter 4 for further details). In Lithuania, the social security agency SODRA uses administrative data to calculate gender pay gaps for employers, eliminating the need for companies to perform these calculations themselves. Denmark’s approach is slightly different: Statistics Denmark, the national statistical office, uses their national linked employer-employee Structure of Earnings Survey to estimate within-company pay gaps. These survey data allow them to link individual workers’ wages to their employers for pay gap analysis purposes.
In other OECD countries, administrative data are used to calculate gender pay gap information for employers in the public sector. In Austria administrative data are used to fully calculate pay gap information in the Federal public service, but not for private sector employers. In Korea, the Ministry of Gender Equality and Family uses wage data extracted from two disclosure platforms – DART (listed companies) and ALIO (public institutions) – to publish annual gender pay gap statistics by industry each September.
In Australia, employers are required to submit raw pay data that are then used by government to calculate pay gap statistics on employers’ behalf. Employers submit raw pay information to a government body – the Workplace Gender Equality Agency (WGEA), which calculates gender pay gaps on their behalf. In New Zealand the Public Service Commission collects data from all agencies and publishes annual system-wide reports on pay gaps by gender and ethnicity across the public service (i.e. not disaggregated by agency).
Estonia has launched a voluntary digital self-service tool, Pay Mirror,15 available for all employers with at least three men and three women employees. The tool uses existing register data to help employers monitor and analyse gender gaps without requiring additional data entry. It provides indicators on gender pay gaps, average and median salaries, gender composition of the workforce and distribution across positions. Data are confidential and accessible only to authorised management, not to third parties or authorities.
While most countries rely on employers to self-identify when they meet company size thresholds for pay reporting, several countries use administrative data – such as tax records, social insurance data, or employment databases – to identify relevant employers. For example, Canada uses data collected under the Canada Labour Code to identify employers subject to the Employment Equity Act, while Korea uses its Employment Insurance database to identify firms subject to Affirmative Action, and Belgium relies on company size information already collected for establishing which organisations are required to hold social elections to determine which companies fall under reporting obligations. Italy, Iceland, Lithuania and Portugal also report using administrative data to identify affected firms.
Pre‑employment salary transparency measures are also starting to gain some momentum, spurred in part by the EU Pay Transparency Directive, which includes relevant requirements (see Box 3.2. ). This section takes stock of OECD country approaches, focussing specifically on salary transparency mandates in job advertisements, requirements for gender-neutral language in job advertisements, and prohibitions barring employers from asking jobseekers about their current or previous salary.
3.8.1. Salary transparency in job advertisements – theory and evidence
Pay transparency in job advertisements involves clearly stating the salary or salary range for a position in a job advertisement, giving jobseekers and employees a clearer sense of expected earnings for a specific job. Salary disclosure requirements have the potential to break down cultures of pay secrecy and to support jobseekers to negotiate more effectively, which could help to address gender pay gaps (OECD, 2023[1]).
In theory, this type of salary transparency could reduce gender pay gaps through several mechanisms. First, it can support more effective negotiation. Evidence from a large‑scale natural field experiment tracking around 2 500 job-seekers responding to real job postings shows that clearly stating the salary range and whether the salary is negotiable significantly increases the likelihood that women negotiate, helping to narrow gender gaps in starting salaries (Leibbrandt and List, 2015[16]) (Mazei et al., 2015[17]). When salary information is unclear or absent, women are more likely to anchor their expectations at the lower end of potential ranges (Bowles and Babcock, 2013[18]), potentially contributing to lower initial compensation that may persist throughout careers (Office for Equality and Opportunity, 2025[19]). Efforts to address social norms around negotiation could be particularly important, as some research suggests that women are more likely than men to face social backlash when they do negotiate, being perceived as “too demanding” (Bowles and Babcock, 2013[18]). Broader research on gender stereotypes in negotiation contexts indicates that cultural biases may privilege men in negotiations and penalise women for displaying assertiveness (Kray, Kennedy and Lee, 2024[20]).
Second, transparency may improve job sorting by enabling workers to identify and apply for better-paying positions. Evidence suggests women are more likely than men to undersell themselves or apply for lower-paying roles when compensation is opaque, and visible salary information may encourage applications to higher paid positions (Roussille, 2024[21]). Third, transparency reduces information asymmetries between employers and jobseekers, making it harder for firms to underpay workers who lack knowledge of their market value. Finally, as more companies adopt transparency, market-wide pressure for improved practices may emerge, compressing unjustified pay variation across firms (Johanson, 2021[22]).
Salary transparency in job advertisements is valuable for workers. Classifying pay and non-pay attributes in 3 million job advertisements in Norway in the period between 2002‑2019, and linking those with measures of employer attractiveness, Audoly, Bhuller and Reiremo (2024[23]) find that publicly listed pay and non-pay related job attributes in job advertisements are predictors of employer attractiveness, showing that the content of job vacancies can help workers assess their options in the labour market. Surveys conducted by job platforms also consistently show that job seekers identify knowing expected compensation upfront as an important factor in job descriptions (Johanson, 2021[22]). In a LinkedIn survey of 450 members, 61% gravitated toward salary information in job postings (2018[24]), cited in (Johanson, 2021[22]), and in a more recent LinkedIn survey, 89% reported that salary ranges in job postings were helpful in deciding whether to apply for a position (2023[25]), cited in (Johanson, 2021[22]). A Glassdoor survey of over 1 100 job seekers found that more than 60% look for salary information and benefits when searching job advertisements (Glassdoor, 2018[26]), cited in (Johanson, 2021[22]).
These results are intuitive; salary transparency allows candidates to assess financial viability before investing time in applications, and to understand market rates for effective negotiation. Cross-firm pay transparency through salary benchmarks and job posting disclosures enables applicants, especially those who are underpaid, to redirect their search toward higher-paying firms to achieve more favourable pay negotiations (Cullen, 2024[27]). Employers also benefit, as salary disclosure can enhance recruitment efficiency and help attract better-matched candidates (Cullen, 2024[27]).
Nevertheless, salary disclosure policies are infrequently used across countries, and evaluations of such policies are rare. As a result, robust evidence on their effectiveness is scarce, making it premature to draw conclusions about whether, how and when salary transparency in job advertisements helps to narrow gender pay gaps. Evidence from Austria paints a mixed picture of effectiveness (see Box 3.1). Robust and systematic evaluation of salary disclosure requirements should be prioritised as interest in salary transparency in job advertisements grows. Rigorous assessment will be essential to identify whether and which design features and implementation strategies are effective in reducing gender pay inequities.
Since Austria implemented a requirement for employers to include salary information in job advertisements (in 2011), several studies have examined how providing publicly available wage information in job vacancy notices affects the gender pay gap.
An early (2015) evaluation of the Austrian law by government points to implementation challenges that constrain efficacy (Bundesministerium für Bildung und Frauen, 2015[28]). While formal compliance was found to be high (87% by 2014), implementation quality varied considerably. Most employers provided only the collective‑agreement minimum salary alongside the generic phrase “Bereitschaft zur Überzahlung” (willingness to pay more), rarely disclosing actual pay ranges or realistic salaries due to concerns about losing negotiation flexibility or disrupting internal pay structures. The report finds that job seekers find these collective agreement figures too uninformative to be useful. Furthermore, implementation rates were higher in low-skill segments where pay approximates collective agreement rates, but lower for higher-skilled occupations and significantly lower for job postings abroad where Austrian regulations do not apply. Regional variation was also notable, with job advertisements in Vienna more frequently including pay data than postings in Western regions.
The evaluation highlighted concerns from a gender equality perspective: while salary information helped entry-level candidates orient themselves, women were far more likely than men to use the posted salary as their negotiation anchor (43% of women versus 24% of men), potentially leading to downward anchoring of women’s pay expectations. Enforcement remained weak, with complaints about missing disclosures extremely rare.
More recent academic research has advanced understanding of the policy’s effects using sophisticated quasi‑experimental methods and addressing different mechanisms. Frimmel et al. (2023[29]) analysed the pay-in-job-ads requirement using a Quantile Difference‑in-Difference model to account for heterogeneous effects along the wage distribution. They found that the reform led to a small overall reduction of the gender pay gap, with reductions particularly pronounced in circumstances where women were uncertain about their market value and when needing to make job acceptance decisions under pressure. Critically, the reduction in the gender pay gap was caused by an increase in women’s earnings, particularly at the lower part of the distribution, while earnings of men remained largely constant – suggesting that even imperfect salary disclosure can improve women’s negotiation outcomes within chosen jobs.
However, Bamieh and Ziegler (2025[30]) examined a different aspect of Austria’s policy, focussing on occupational sorting patterns rather than within-job earnings. Using detailed occupation-firm cells that explain about 75% of variation in wage postings, they estimate a substantial gender gap of 15 log points but find that mandatory wage postings do not affect gender sorting into better-paying occupations and firms. Their analysis suggests that the policy failed to alleviate the gender gap through improved worker information about pay differences across occupations and employers – while transparency may help women negotiate better wages within their chosen occupation-firm combinations (consistent with Frimmel et al.’s findings), it does not necessarily shift women’s sorting decisions toward higher-paying job categories.
In the Slovak Republic, Skoda (2022[31]) studied the 2018 law requiring firms to include expected salaries in all job advertisements and found that the wages of new hires increased by 3% in firms that had not previously disclosed salary information. The reform also led job applicants to apply to a more diverse set of opportunities, spanning a greater number of sectors and wider array of job titles, suggesting that transparency helped workers better direct their job search toward suitable opportunities. The study found that before the law, the share of job postings with salary information ranged from 10% to 60% depending on job title; after the reform, nearly all job titles listed expected pay.
These studies illustrate the importance of examining multiple mechanisms through which transparency policies might operate, and the importance of robust evaluation. Early descriptive evaluations identified implementation quality challenges and potential anchoring effects. More recent causal research suggests that even low-quality disclosure can improve women’s within-job bargaining outcomes (reducing the gap by helping women negotiate higher starting salaries), but in Austria it does not seem to have addressed the broader occupational segregation that explains much of the overall gender pay gap. For governments looking to implement salary transparency in job advertisements, these findings highlight the importance of disclosure specificity (i.e. ensuring that disclosed salary information is realistic), and the importance of implementing such a requirement alongside broader measures to tackle pay gaps and their drivers, including deeply embedded occupational segregation patterns.
Source: Bundesministerium für Bildung und Frauen (2015[28]), Einkommenstransparenz: Gleiches Entgelt für gleiche und gleichwertige Arbeit – Evaluierung der Maßnahmen zur Einkommenstransparenz; Frimmel et al. (2023[29]), External Pay Transparency and the Gender Wage Gap; Bamieh and Ziegler (2025[30]), Can wage transparency alleviate gender sorting in the labour market?; Skoda (2022[31]), Directing job search in practice: mandating pay information in job ads.
3.8.2. A handful of countries mandate salary transparency in job ads
As of July/August 2025, only five OECD countries – Austria, Japan, Latvia, Lithuania and the Slovak Republic – have a national requirement for private sector employers to disclose the starting salary or salary range of jobs in job advertisements. Such requirements have been in place for over a decade in Austria (introduced in 2004 and amended in 2011 and 2013), and were introduced more recently in Japan (2022),16 Latvia (2018), Lithuania (2019) and the Slovak Republic (2018).
All five countries mandate salary disclosure for both public and private sector organisations, though in Latvia the regulation does not cover public sector recruitment for civil servants (Latvia reports that in practice public sector employers opening competitions for civil service positions tend to include salary information in the announcement).17 The requirements generally apply to all private sector employers in Austria, Japan, Latvia, Lithuania and the Slovak Republic irrespective of company size or the type of employer recruiting. In the Slovak Republic, however, the requirements do not apply to legal entities recruiting workers willing to work on a self-employed basis.18
Disclosure requirements are broadly similar across all five countries but differ somewhat in the types of information to be provided, the posts to which they apply, and the strength with which they are monitored and enforced (described in further detail below). The number of countries that mandate salary disclosure in job advertisements could increase as EU countries transpose the EU Pay Transparency Directive, though this will depend on how countries choose to implement the Directive: the Directive extends a right to jobseekers to receive salary information prior to employment, but it does not require employers to provide such information specifically in job advertisements (Box 3.2).
Interestingly, job platform data suggests that in some countries, many employers voluntarily include salary information in job advertisements even where there is no legal mandate for them to do so. For instance, Reuters reports – relying on job platform data – that 71% of employers in the United Kingdom using job platform Indeed provide salary information in job advertisements, followed by 50% in France, 45% in the Netherlands, 41% in Ireland, 20% in Italy, and 16% in Germany (Milliken, 2025[32]).
The EU Pay Transparency Directive seems likely to drive greater salary transparency in job advertisements across the EU – and by extension, across OECD countries – yet much depends on how it is implemented. The Directive mandates pay transparency to applicants prior to employment, but does not explicitly mandate salary disclosure in job advertisements. Rather, the Directive extends a right to applicants for employment to receive information on the starting salary or salary range from prospective employers (and where applicable, relevant provisions of the applicable collective agreement), with such information provided in a way that ensures an “informed and transparent negotiation on pay, such as in a published job vacancy notice, prior to the job interview or otherwise.” Countries are accordingly afforded some leeway as to implementation of the principle, as the Directive leaves scope for varying implementation in:
When in the recruitment process employers are required to provide salary information to jobseekers – which the Directive suggests could be in the job advertisement, prior to the interview or at another time; and.
How the information is provided, for example whether in writing, or if verbal advice is acceptable.
As such, implementation of the principle could vary across countries, and early indications suggest that it is likely to do so. In the EU OECD countries that have tabled legislation or published proposals to transpose the Directive, there is variation as to employers’ requirements: in some settings it is suggested that employers include salary information in job advertisements, while some countries leave the choice to employers. In Poland, since December 2025 employers have been required to provide applicants for employment with the starting salary or salary range for a given position, in the job advertisement, before the job interview, or before entering into an employment contract. This information must be given in sufficient time to allow the applicant to understand it and negotiate. Conversely, the Belgian region of Fédération Wallonie‑Bruxelles has passed legislation which explicitly requires the information to be made available as soon as job offers or job advertisements are published.
Proposals and/or draft legislation to transpose the Directive in Finland, Ireland, the Netherlands and Sweden also take varying approaches: a draft bill in Ireland calls for employers to disclose salary information in job advertisements, while proposals in Finland and Sweden and draft legislation in the Netherlands effectively leave the choice to employers. In Finland the proposal suggests that employers should provide the information “as early as possible in the recruitment process.” The Swedish proposal and draft Dutch legislation do not specify when or how the information should be provided, though the Swedish proposal suggests that it may be appropriate for employers to be required to provide it in writing, to enable them to prove that it has been provided.
Source: Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms, Chapter II, Article 5 (pay transparency prior to employment), https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:32023L0970. Belgium: Ministry of the French Community (2024[33]). Finland: Ministry of Social Affairs and Health (2025[34]). Ireland: Department of Children (2025[35]). The Netherlands: Overheid.nl (2025[36]). Poland: Journal of Laws (2025[37]). Sweden: Ministry of Labour (2024[38]).
What needs to be disclosed in job ads?
In the five countries that require private sector employers to include salary information in job advertisements, the pay information that employers are required to include is broadly similar (see Table 3.2). Employers are generally required to include the starting salary or salary range (in Japan, Latvia, Lithuania and the Slovak Republic). Austria requires employers to indicate the specific starting salary or the minimum salary set out in the relevant collective agreement. No countries require employers to include complementary variables to salary, such as bonuses or in-kind compensation,19 and no countries explicitly require employers to include gender-relevant non-pay information, such as information on work-life reconciliation supports such as flexible or part-time working.
In Japan, a salary range is permitted only if it reflects possible starting salaries and does not include future wage increases. Disclosure requirements become progressively more detailed as candidates advance through the recruitment process: while basic wage information must appear in job advertisements, employers must provide comprehensive breakdowns – including wage calculation methods, allowances, and information on wage increases – when candidates reach the interview stage. In Austria, evidence suggests that collective‑agreement-only disclosures may provide limited transparency for applicants, given that the gap between the negotiated minimum and actual salaries can be substantial and not easily interpretable (Bundesministerium für Bildung und Frauen, 2015[28]). The disclosure of wide salary ranges in job advertisements may similarly limit the extent to which this type of transparency is useful for applicants.
Note: Information is current as of July/August 2025, when the bulk of data collection took place.
Source: 2025 OECD Pay Transparency Questionnaire.
There is variation across countries as to whether employers are permitted to make an offer below or over the salary range listed in the job advertisement which could mute the expected impact of such a measure on the gender pay gap given gendered differences in wage expectations and negotiation can contribute to gender pay inequalities. In Japan,20 Latvia and Lithuania employers are not barred from making an offer below or above the stated starting salary or salary range, while in Austria and the Slovak Republic employers are prohibited from making an offer below the salary information listed in the job advertisement. These provisions can help to guard against the inclusion of misleading information in job advertisements, strengthening the effectiveness of salary transparency measures in reducing gender pay inequalities. While in Costa Rica there is no salary transparency obligation, any employer that does list a salary range in a job advertisement is prevented from making a job offer below the range they listed.
Available evidence suggests that additional information in disclosure requirements could potentially help to reduce gender inequalities in recruitment outcomes (see Box 3.3). First, countries could consider requiring employers to state not only the salary or salary range, but also whether the salary is negotiable. Field experiments demonstrate that clearly stating whether negotiation is possible significantly increases the number of women who negotiate, helping to reduce gender gaps in starting salaries (Leibbrandt and List, 2015[16]). Countries could also consider requiring disclosure of work-life reconciliation supports, particularly flexible and part-time working arrangements, which could help to promote more gender equitable outcomes (see Box 3.3). The “motherhood penalty” – the negative impact of parenthood on women’s labour market participation and pay – remains a major contributor to the gender pay gap. It reflects the greater time mothers spend out of work and the difficulties many face when returning to work, including challenges reconciling work and care, slower career progression, and discrimination from employers (OECD, 2025[39]; 2023[1]).
Field trials show that advertising roles as available for part-time work or job-sharing substantially increases the total applicant pool while particularly increasing applications from women, helping employers attract talent while promoting gender equality. Research with Zurich Insurance found that making the default option to advertise all roles as open to part-time working increased applications from women to senior roles by 19%, with few hiring managers opting out (Davidson, 2020[40]). Similar effects were observed at John Lewis and Partners (35% increase in applications from women to senior roles) and on the global job site Indeed (19% to 30% increase in total applicant pools) (Office for Equality and Opportunity & Behavioural Insights Team, n.d.[41]).
Including information on work – life reconciliation supports in job advertisements, such as flexible and part-time working arrangements, could consequently help to promote gender equality in recruitment and broaden the pool of applicants (Wodak and Freeburn, 2024[42]) (Davidson, 2020[40]). Importantly, how flexibility options are framed and communicated seems to matter: studies also show that job advertisements that are specific about the flexibility arrangements available are more appealing to women. For example, in an online experiment conducted by the Behavioural Insights Team with 460 women currently and recently returning to work, job advertisements specifying “flexibility as to working hours, days and location”– were three times more likely to be chosen by women returners compared to those with more generic flexibility offers such as “flexible work available” (Wodak and Freeburn, 2024[42]).
Simple interventions can increase the likelihood that employers include gender-relevant information in job advertisements. Field trials with employers advertising on online job platforms found that prompting hiring managers to clearly list specific flexible working options led to a 20% to 30% increase in employers advertising flexible jobs (Office for Equality and Opportunity & Behavioural Insights Team, n.d.[41]), suggesting that providing templates, guidance, or defaults within recruitment systems can significantly improve the quality of disclosures without imposing substantial burdens on employers.
Source: Davidson (2020[40]), Switching the default to advertise part-time working boosts applications from women by 16%; Office for Equality and Opportunity and Behavioural Insights Team (n.d.[41]), “How to improve gender equality in the workplace: actions for employers”; Wodak and Freeburn (2024[42]), “How reframing flexible working can drive up female recruitment”.
Which job advertisements?
The types of posts covered by salary transparency requirements in the private sector vary: while employers in all five OECD countries with such requirements are required to include salaries in publicly advertised (“external”) posts, fewer countries require employers to list salary information for internal job posts (e.g. transfers), and/or for promotions. The Slovak Republic requires employers to include the information in internal postings, and in Austria the rules apply to external postings, internal postings and promotions (see Table 3.3). Some sub-national salary transparency mandates explicitly cover promotions and/or transfers, too.
Note: Information is current as of July/August 2025, when the bulk of data collection took place.
Source: 2025 OECD Pay Transparency Questionnaire.
3.8.3. Monitoring compliance with salary transparency requirements
Countries take differing approaches to monitoring compliance with salary transparency requirements. Japan, Latvia, Lithuania and the Slovak Republic report that government bodies oversee compliance, whereas Austria does not monitor compliance. Among countries that do monitor, approaches vary considerably – from proactive and regular monitoring to verify whether employers include salary information in job advertisements, to ad hoc checks when complaints or concerns are raised.
Lithuania reports that the state Labour Inspectorate regularly monitors whether employers include salary information in job advertisements. In Latvia, compliance is supervised as part of broader oversight of employment and labour laws. In the Slovak Republic, monitoring is primarily complaint-driven: the government checks job offers published on the State Job Portal, but private portals and social media are not monitored.21 In Japan, oversight is carried out by Prefectural Labour Bureaus, Public Employment Security Offices (Hello Work), and District Transport Bureaus (for seafarers).
Enforcement approaches also vary across countries, with possible levers for enforcement ranging from consultations, guidance, advice and/or warnings (among possible approaches in Japan, Latvia and the Slovak Republic), reprimands (in Austria), orders to improve (Japan) or orders to observe the requirements (Latvia), financial penalties for non-compliance (in Austria, Japan, Latvia, Lithuania and the Slovak Republic) or even imprisonment (in Japan, though this relates to employers who make false statements in job advertisements as to employment conditions) (see Table 3.4). In Austria and Lithuania the severity of enforcement action increases for repeated violations. Potential fines range from EUR 240 in Lithuania to EUR 1 690 in Japan – where fines relate to false statements in job advertisements. Enforcement of the rules is designated to state labour inspectorates in Latvia, Lithuania and the Slovak Republic, while in Austria the district authority is responsible for enforcing compliance with the rules.
Note: 1. In Latvia, fines range from 7‑70 units for natural persons, or from 14‑22 units for a legal entity; as of July/August 2025, this translates to the financial values listed in this table.
Source: 2025 OECD Pay Transparency Questionnaire.
3.8.4. Public sector and sub-national salary transparency requirements
Requirements for salary transparency in job advertisements are more commonly reported in the public sector than in the private sector across OECD countries. Several OECD countries without such a mandate for private sector employers do require that at least some public sector employers make salary information publicly available to jobseekers:
in Norway, state level public sector employers are required to include salaries in job advertisements, and the salary offered must fall within the advertised range. Municipal-level organisations are not subject to this requirement; and
In Portugal, Ordinance 233/2022 requires public sector organisations to include the salary or salary level in job advertisements in competitive recruitment processes.
In other OECD countries this is recommended or reported to be common practice. Public sector guidance in New Zealand recommends that job advertisements include the salary range and any additional pay benefits, while Costa Rica, Iceland22 and Switzerland report that it is common practice for public sector employers to include starting salaries in job advertisements, even though this is not required by law. More exceptionally, Latvia mandates salary disclosure for workers employed under labour contracts in the public and private sector, but this does not extend to civil servants recruited through competitive processes, which are regulated separately. In practice, however, Latvia reports that public sector organisations typically do include salary information in the announcements. Luxembourg reports that salary scales for public sector agencies are made publicly available (salaries and salary progression), even if they are not specifically mandated to be included in job advertisements. Salary disclosure requirements in job advertisements are also being implemented sub-nationally, for example in Belgium and Canada (non-exhaustive list).
Some other OECD countries mandate salary transparency prior to employment in the private sector without explicitly requiring employers to include salary information in job advertisements. For example in Czechia, employers are required to inform jobseekers about pay prior to the formalisation of an employment contract, though when and how employers are required to share this information is not specified, while in Italy, employers are required to share salary information at the time that the employment relationship is established (e.g. by providing the employment contract) and prior to the commencement of work (examples in this paragraph are non-exhaustive).
As can be seen from these examples, the timing at which salary disclosure is mandated varies, which could reasonably be expected to affect the scope for jobseekers to negotiate their wages, and how easily jobseekers can use the information to “sort” into jobs with salaries commensurate to their level of skill and experience (i.e. listing salary in a job advertisement would make it easier for jobseekers than finding out the salary at the time of drawing up a contract, by which time a jobseeker may already have expended considerable time and effort in a recruitment process). Greater transparency (e.g. publicly listing expected salaries) could also help to narrow scope for discrimination by employers.
3.8.5. Can employers request or consider information on a candidate’s salary history during recruitment?
Some countries are implementing bans that prohibit employers asking jobseekers about their salary history during the recruitment process. These bans can help ensure that wages are attached to the work to be performed rather than the worker performing it, and could help break traditions of underpayment for historically underpaid workers (many of which are women). This principle is reflected in the EU Pay Transparency Directive, which prohibits employers from asking applicants about their current or previously-held salary.
As of July/August 2025, Poland was the only OECD country that had passed national legislation that explicitly prohibits private sector employers from asking applicants about their salary history during the recruitment process and/or from considering their salary history in decisions about their pay (though an amendment to the Labour Code – which transposed parts of the EU Pay Transparency Directive and came into effect in December 2025).23 The amendment does not explicitly state whether employers can consider jobseeker’s salary history in decisions about their pay (for example, if the applicant volunteers the information even where it was not requested). In some countries there are sub-national bans prohibiting private sector employers from requesting jobseekers’ salary history, including in Belgium and the United States.
In other countries, broader non-discrimination laws may prohibit employers from requesting or considering jobseekers’ salary history, even if this is not explicitly stated, based on the assumption that employers should not take a salary history into account during the recruitment process because it is not a “relevant” factor for determining a candidate’s suitability or remuneration for a job. This implicit obligation stems mainly from broader provisions in labour and/or non-discrimination law which require employers to assess only factors that are directly relevant to recruitment and/or wages, such as the job to be done and the suitability of the jobseeker to do it. For example:
In Czechia, the Labour Code grants a right to equal pay for equal work or work of equal value, thereby implying an obligation for employers to base pay decisions on the value of the work to be performed. This implies that a jobseeker’s pay history with prior employers is not a relevant factor in decisions about their pay.
In Estonia, the Employment Contracts Act prohibits employers from asking applicants for information during pre‑contractual negotiations for which the employer has no “legitimate interest,” including information not relevant to their suitability for the role. This could imply that employers should not request salary history.
In France, the Labour Code stipulates that information that employers request from candidates must be aimed solely at assessing the candidate’s professional skills or their ability to do the job, potentially implying that employers should not request salary history.
In Israel, under the Equal Employment Opportunities Law, employers are required to base hiring decisions solely on relevant qualifications. This could imply that employers should not ask candidates about their salary history, as this could lead to indirect discrimination or an offer that does not reflect their professional value.
In Latvia, labour law prohibits interview questions that are not relevant to the work or the employee’s ability to perform it, thereby suggesting that employers should not pose interview questions related to a jobseekers’ prior salary history.
In Norway’s public sector, provisions on equal pay for equal work or work of equal value imply that prior salary is not a relevant factor in determining wages.
In Slovenia, the Employment Relationships Act24 stipulates that employers may only require candidates to provide evidence that they meet the conditions needed to perform the work. It also prohibits employers from requesting information not directly related to the employment relationship when concluding an employment contract.
However, these implicit obligations may present enforcement challenges. It may also be less clear to workers – and therefore less understood by workers – that employers are not permitted to request such information (if applicable).
By contrast, some legislation explicitly allows employers to take a candidate’s salary history into account. The Canadian province of Ontario takes this approach. In Ontario, employers are barred from asking about salary history, but jobseekers can provide it voluntarily. Where a jobseeker does so, or where an employer otherwise becomes aware of their salary history, the employer is not prohibited from considering or relying on that information in determining pay.25
3.8.6. Few OECD countries explicitly mandate gender-neutral language in job advertisements
Gender-neutral language in job advertisements is another potential mechanism by which to promote greater gender equality in recruitment and wages. Gendered stereotypes and social norms about what constitutes appropriate work for women and men contribute to the concentration of women in low-paying jobs (see OECD (2023[1]) for are more detailed discussion). Avoiding gendered language in job advertisements could help to weaken these stereotypes and help address occupational segregation by encouraging men and women to more equitably consider and apply for posts that have historically been considered as “women’s” or “men’s” jobs. This principle is reflected in the EU Pay Transparency Directive, which requires employers to ensure that job vacancy notices and job titles are gender neutral, and that recruitment processes are led in a non-discriminatory manner.
While no known evidence shows that gender-neutral language in job advertisements directly affects the gender composition of applications to posts, research demonstrates that gendered language can make jobs less appealing to women. Using words associated with masculine stereotypes (e.g. ”competitive” or “dominant”) can lead women to assume those roles are in male‑dominated teams where they may not fit (Gaucher, Friesen and Kay, 2011[43]), and emphasising traits culturally associated with men can undermine women’s interest in opportunities (Bian et al., 2018[44]). Using neutral language in job advertisements could accordingly help attract a wider pool of talent (Office for Equality and Opportunity, 2025[19]).
Many OECD countries have legal mandates that prohibit discrimination in the recruitment process, including in job advertisements, and therefore prohibit employers from “targeting” jobs to men or women only (though these mandates often include exceptions or “carve‑outs,” for example if it is essential that the role be performed specifically by men or women, such as for privacy reasons). Beyond ensuring that job advertisements do not explicitly exclude men or women, requirements on gender-neutral language can help to ensure that job advertisements do not implicitly exclude men or women, for example by using only the “male” or “female” version of job titles, using language typically associated with male‑dominated tasks or professions, or using other signals that suggest jobs should be performed by men or women.
Only a handful of countries report explicit, national-level requirements related to gender neutrality in job advertisements beyond broader non-discrimination protections that prohibit employers from targeting advertisements to men or women. These requirements tend to focus on ensuring that the language and the description of tasks do not imply that the job should be performed by men and/or women, or on ensuring that job titles are gender neutral. In the Netherlands,26 for example, employers are required to write job advertisements in a way that makes it clear that both men and women are eligible to apply, and to use the male and female form of job titles, where job titles are used (or otherwise, to expressly state that both women and men are eligible). Austria27 also requires employers to ensure that job advertisements do not imply that men or women specifically would be preferred (examples in this paragraph are non-exhaustive).
A number of relevant requirements have been implemented more recently, or at sub-national level. A recent amendment to the Labour Code in Poland has since December 2025 required employers to ensure that job advertisements and job titles are gender neutral. In Belgium, sectoral collective agreements are subject to central control/review, and where job classifications contain a mix of masculine and feminine job titles, they are considered to fail the gender-neutrality test (see the case study on Belgium in Chapter 4).
As EU countries transpose the EU Pay Transparency Directive, clear guidance for employers on how to implement gender neutrality in job advertisements – and on the reasons and/or expected benefits of doing so – could be particularly valuable. Literal transposition may leave interpretation and implementation to employers’ discretion, with variable outcomes.
In other countries, provisions on indirect discrimination may implicitly require gender neutrality in job advertisements. Some countries have provisions on indirect discrimination in recruitment which could broadly imply a requirement for gender neutrality in job advertisements, even though not stated explicitly (examples in this paragraph are non-exhaustive). For example, Italy prohibits indirect discrimination “…through pre-selection mechanisms…or with any other form of advertising that indicates as a professional requirement belonging to one or the other sex…”, and in Portugal job advertisements cannot contain “…any restriction, specification, or preference based on sex,” whether directly or indirectly. Under a broad interpretation, these types of requirements could suggest that employers should not use gendered language suggesting that work should be performed specifically by men or women. However, enforcement could be less straightforward.
3.8.7. What other steps are being taken to promote salary transparency prior to employment?
In some countries, government and/or social partners have developed guidance or recommendations to encourage gender-neutral and pay-transparent job advertisements. In Canada, a bulletin was issued in 2023 to all heads of human resources and chiefs of classification in the public sector on the importance of using inclusive language in job descriptions and job titles, and providing resources on inclusive writing (Government of Canada, 2023[45]). New Zealand has made guidance available on eliminating bias in the recruitment process, including recommendations to list salary ranges in job advertisements together with additional pay benefits, and to ensure that language in job descriptions is free from (gender) bias. In the Netherlands, a network of HR professionals teamed up with social partners to develop a “Solicitation Code” which includes a recommendation not to request a candidate’s salary history, while in the United Kingdom Government guidance encourages employers to be transparent about pay to promote gender equality. To promote greater pre‑employment salary transparency, Czechia banned pay secrecy clauses (confidentiality clauses related to pay) in employment contracts in 2025.
Public pay gap reporting can also increase transparency prior to employment by making firm-level gender pay gaps visible to jobseekers. This could promote gender pay equity by helping workers seek out firms with lower pay gaps, and by providing an additional incentive for employers to reduce gender pay gaps to attract talent. As outlined earlier in this chapter, several OECD countries make firm-level gender pay gaps publicly available, meaning they can also be accessed by jobseekers.
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← 1. Pay reporting laws in Canada only apply to federally regulated private sector employers, federally regulated Crown corporations, and other federal organisations (under the Employment Equity Act) and to federally regulated private and public sector employers, parliamentary workplaces, and the Prime Minister’s and ministers’ offices (under the Pay Equity Act). Information presented relates to obligations under the Employment Equity Act and Pay Equity Act.
← 2. The pay reporting law in Chile only applies to businesses under the supervision of the Financial Market Commission [Comisión para el Mercado Financiero (CMF)]. The Financial Market Commission (CMF) is a public service of a technical nature whose main objectives are to ensure the proper functioning, development and stability of the financial market, facilitating the participation of market agents and promoting the care of public faith. Companies analyse their gender equality, taking remuneration into account, in order to comply with CMF rules.
← 3. France’s response to the 2025 OECD Pay Transparency Questionnaire covered private sector arrangements only. Information for France in this chapter relates exclusively to the private sector, unless specifically indicated otherwise.
← 4. In Portugal all firms with at least one employee must submit a “Single Report” but equal pay audits are only required for firms with 50+ employees if gaps are found.
← 5. The pay reporting laws in Canada only apply to federally regulated private sector employers, federally regulated Crown corporations, and other federal organisations (under the Employment Equity Act) and to federally regulated private and public sector employers, parliamentary workplaces, and the Prime Minister’s and ministers’ offices (under the Pay Equity Act).
← 6. In Australia, rules between public and private sector organisations vary to some extent in their terminology, and the respective reporting periods. The requirements do not apply to public sector employers at the state and territory levels.
← 7. For more information on pay reporting in Switzerland, see OECD (2023[1]): Switzerland is a special case where employers must report on pay information once, and if equal pay requirements are met, they are exempt from future reporting (the prevalence of once‑and-done assessments is not assessed). Otherwise, employers are required to report every four years. Although the law does not appear to provide clear criteria for when a pay equality is achieved, i.e. whether the equal pay requirements are met, in practice the pay gap must not be statistically significantly greater than 5%, when conducting the analysis with Logib (see Chapter 7 of the 2023 OECD report for more information).
← 8. In the 2025 OECD Pay Transparency Questionnaire, countries were asked to provide data on the estimated share of workers and/or companies that are covered by pay gap reporting requirements in the private sector.
← 9. In Portugal all firms with at least one employee must submit a “Single Report” but equal pay audits are only required for firms with 50+ employees if gaps are found.
← 10. The requirement relates to a physical location under the control of an employer, and not a remote workplace location such as a home address.
← 11. Decree amending the Decree of 12 December 2008 on the fight against certain forms of discrimination, at 15/3.
← 12. Korea maintains multiple public disclosure systems operating independently of its “Affirmative Action” (AA) reporting framework: ALIO for public institutions, Clean-Eye for local public enterprises and corporations, and DART for publicly listed companies. While the AA system requires wage reporting from these entities, the public disclosure platforms operate under separate legislation and provide transparent access to wage information for different organisational types.
← 13. In the context of public procurement and subsidies, Switzerland has a monitoring system operating across multiple federal levels, supported by the Swiss Office for Gender Equality (EBG) who plays a central role in harmonising the methodology. At the federal level, EBG conducts approximately 30 annual pay equity audits of companies receiving federal public contracts, with sanctions including exclusion from future contracts possible in cases of non-compliance. Under the Charter on Pay Equity in the Public Sector – signed by 17 cantons, over 100 municipalities, and over 100 quasi-public enterprises – cantonal and municipal authorities are also conducting pay equity inspections in the areas of procurement and/or subsidies, with activity at the cantonal and municipal levels now exceeding 100 audits per year and expanding further (300 audits at all federal levels according to a 2023 study commissioned by the Swiss Office for Gender Equality). What remains lacking is general enforcement of the Gender Equality Act analysis requirement for private sector companies outside the procurement and subsidies context.
← 14. In the 2025 OECD Pay Transparency Questionnaire, countries were asked if they monitored private sector companies’ compliance with the reporting requirements, and if so, whether they adopted a “proactive” approach, or a “reactive” approach.
← 15. More information is available on the website of the Ministry of Economic Affairs and Communications: https://www.mkm.ee/too-ja-vordsed-voimalused/vordsed-voimalused-ja-sooline-vordoiguslikkus/palgapeegel.
← 16. In Japan, salary disclosure requirements were introduced gradually through amendments to the Employment Security Act. Article 5‑3, which requires employers to provide wage information at later stages of the recruitment process (e.g. when a jobseeker applies for an interview or prior to a placement agency referral), has been in force since 1 December 1947. By contrast, Article 5‑4 – which applies specifically to job advertisements, including those published online, and requires employers to indicate the starting salary or starting-salary range – entered into force much later, on 1 October 2022.
← 17. The legal obligation to disclose starting salary in job advertisements applies to people working based on employment contracts, including in the public sector. However, the requirements do not apply to civil servants as the State Civil Service Law regulates the open candidate competition announcement and does not require information about salary to be included in job advertisements. Latvia reports that in practice, public sector organisations do tend to include salary information in the announcements.
← 18. The obligation also does not apply where employers are legal entities based outside of the Slovak Republic, recruiting Slovak citizens outside of the Slovak Republic.
← 19. While this information is not required to be included in the job advertisement, some countries nonetheless have rules or regulations which require this information to be provided at a later stage in the recruitment process, prior to conclusion of the employment contract.
← 20. In Japan, employers concluding an employment contract with conditions that differ from those in the advertisement are required to clearly indicate the changes to jobseekers prior to concluding the contract. Employers can be subject to penalties if false employment conditions are indicated in job advertisements.
← 21. As of October 2025, this function was performed by the Office of Labour, Social Affairs and Family and the Central Office of Labour, Social Affairs. Slovak Republic reports that this competence will pass to the Labour Inspectorate(s) once new legislation on pay transparency (to transpose the EU Pay Transparency Directive) comes into effect.
← 22. In Iceland, regulations generally require public sector organisations to advertise all positions and reference the “terms of employment” in the advertisement. Iceland reports that in practice, it is customary for public sector employers to refer to the relevant collective agreement for the position or to state that salaries are determined in accordance with the current collective agreement concluded between the Minister of Finance and Economic Affairs and the relevant trade union.
← 23. Based on country responses to the 2025 OECD Pay Transparency Questionnaire, supplemented by desk research for Ireland and the United States. Canada’s response only covers the Employment Equity Act, and the Pay Equity Act.
← 24. Article 28 of the Slovenian Employment Relationships Act (ZDR‑1).
← 25. Pay Transparency Act, 2018, S.O. 2018, c. 5 – Bill 3, Chapter 5, Section 5 on Compensation History.
← 26. Equal Treatment of Men and Women Act, Article 3(3)‑3(4).
← 27. Federal Equal Treatment Act, § 7. (2) (federal civil servants only, not at state or community level) requires employers to ensure that the requirements and tasks of a job are written in such a way that they “affect” men and women equally, and to ensure that the advertisement does not contain additional comments that suggest a specific gender.