Global Pay Reporting Cheat Sheet

Christine Hendrickson, VP of Strategic Initiatives & Ritu Mohanka, Managing Director, EMEA, July 14, 2022

Every country’s laws around pay differ. Some have laws requiring equal pay that are only minimally enforced, while others have robust enforcement and reporting requirements. Some focus on pay equity, while others primarily look at pay gaps. Some countries require that you report on pay equity or pay gap statistics if you are a company that meets a certain headcount threshold. 

For companies with a global workforce, pay equity can seem daunting due to complexities like the different approaches to pay equity, data privacy, a web of different reporting requirements, and differences in employee thresholds and deadlines. 

To help you get a handle on global pay reporting, our team of experts has compiled a cheat sheet that covers pay reporting laws and requirements in 15 key jurisdictions across the world — and guidance for how leading brands are approaching global pay equity.

 

Current global pay reporting requirements

Country Requirement Reporting Threshold Coverage Frequency
Australia All non-public sector employers with 100 or more employees must submit an annual report on gender equality to the federal Workplace Gender Equality Agency. The report includes a questionnaire with questions related to the company's strategies and actions on gender equality; workplace management statistics (including promotions, resignations, and parental leave); and workplace profile that includes pay information including, for example, aggregated average base salary and total remuneration of male and female employees in various occupational categories. 100 employees; additional obligations apply to employers with 500+ employees Annually with report due 31 May
Belgium Must ensure gender-neutral job classifications and remuneration structure within the company and create a report that makes it possible to determine whether the company applies a gender-neutral remuneration policy. Detailed analysis required for employers with 100+ employees and more limited reporting for employees between 50-100 employees, following templates created by Ministerial Decree. An average of 50 employees; additional obligations apply to private employers with 100 or more employees Every two years
Canada At the federal level, federally-regulated employers with 10+ employees must establish and periodically update a pay equity plan. To do so, employers must: (1) identify the different job classes made up of positions in their workplace; (2) determine whether each job class is predominantly male, predominantly female or gender neutral determine the value of work of each predominantly female or male job class; (3) calculate the compensation of each predominantly female, or male job class, and (4) compare the compensation between predominantly female and male job classes doing work of equal or comparable value. Pay increases to any predominantly female job classes that are receiving less pay than their male counterparts may be required. Additional pay equity obligations apply in many Canadian provinces. 10 employees Employers have to establish their pay equity plan within three years of becoming subject to the Act. Plans need to be updated every five years.
Denmark An employer with a minimum of 35 employees must each year prepare a report to be shared internally that shows the wage statistics for men and women by job function (using 6-digit DISCO code) for each job function with a minimum of 10 persons of each gender. 35 employees of at least 10 of each gender in the same work function Annual with internal reporting by 31 December
Finland Employers with at least 30 employees must prepare a gender equality plan. The gender equality plan may be incorporated into a personnel and training plan or an occupational safety and health action plan. The gender equality plan must be prepared in cooperation with the shop steward, the elected representative, the occupational safety and health representative, or other representatives appointed by the employees. The representatives of the personnel must have sufficient opportunity to participate and influence the preparation of the plan. The plan must include de-identified data that shows the number of men and women in different roles, a survey of the job grades in which men and women work, a pay survey, pay gaps, and actions needed to ensure gender equality. A new law that would allow employees to obtain the pay of their coworkers, if they suspect discrimination, is under consideration in Finland. 30 employees Every two years and made available to a representative chosen by the employees
France The law requires companies with more than 50 employees to calculate their Gender Equality Index based on 5 indicators (4 if below 250 employees). The indicators: (1) the pay gap between men and women: (2) the gap between salary increases between men and women; (3) the gap between rate of promotions of men and women; (4) the number of women who received a salary increase when returning from maternity leave; and (5) the number of women in the top 10 wage earners. The index can reach a max of 100 points. If companies fail to reach 75 points for three years, fines of up to one per cent of their expenditures on wages can apply. Companies with more than 1,000 employees also need to calcuate the gender statistics for top executives and members of governing bodies. 50 employees; additional obligations for employers of 1,000+ employees Annual
Germany Employers with 200 or more employees within a business unit must respond to employee requests for information about the criteria for determining the employee's pay as well as information about the base pay plus up to two additional components of pay of comparable employees. Employers of 500 or more emplyees may but are not required to conduct a review to ensure they are taking measures to ensure pay equity. There is mandatory pay equity reporting for companies regularly employing more than 500 employees if the employer is subject to reporting obligations under the German Commercial Code (Handelsgesetzbuch – HGB). " 200 employees (right to information); 500 employees (pay reporting) Employee data (upon request and no more often than once every two years); mandatory pay report for covered employers once every three years (five years if covered by collective bargaining agreement)
Iceland The law requires that women, men and persons whose gender is registered as neutral in Registers Iceland shall be paid equal pay and enjoy equal terms of employment for the same jobs or jobs of equal value. In addition, employers are required to obtain equal pay certification. The certification shall meet the requirements of the Standard ÍST 85, Equal Wage Management System – Requirements and guidance (normally called The Equal Pay Standard). Equal pay certification under the Standard ÍST 85 is designed to confirm that when decisions on wage are taken they are based only onl legitimate factors. An employer which employs an average of 25– 49 employees can choose to either undergo an equal pay certification or to receive an equal pay confirmation following the submission of documentation showing that its equal pay system and its implementation comply with the requirements of the Directorate of Equality for the confirmation. 25 employees; a company which employs an average of 25– 49 employees can choose to either undergo an equal pay certification or to receive an equal pay confirmation following the submission of documentation showing that its equal pay system and its implementation comply with the requirements of the Directorate of Equality for the confirmation. Annual (equal pay certification)
Ireland Employers must calculate the total ordinary pay, total bonus, benefits in-kind received, and total working hours of each employee and use this information to calculate the hourly remuneration. Employers must also identify which workers are full-time, part-time, and on temporary contracts. The report will show: (1) the percentage difference in mean and median hourly remuneration of male and female relevant employees, part-time employees, and those on temporary contracts; (2) the percent difference between the mean and median bonus remunerations of relevant male and female employees; (3) the percentage difference between relevant male and female employee who were paid bonus remuneration; (4) the percentage difference between relevant male and female employees who received benefits in kind; and (5) the percentages of all relevant employees within four hourly remuneration quartile pay bands. 250 employees in 2022; 150 employees in 2024; 50 employees in 2025 Annual with December filing date; employers can choose any June date for the snapshot report with filing due 6 months after the chosen snapshot date
Netherlands There is not current legislation requiring pay reporting. There is pending legislation — “Equal Pay for Women and Men” — that would require employers with 50+ employees to apply for a certificate demonstrating equal pay between men and women. Currently N/A Currently N/A
Norway Employers with 50 or more employees must examine and report in annual reports: (1) whether there is a risk of discrimination or other obstacles to equality; (2) analyze wage conditions distributed by gender and the use of involuntary part-time work (only required every other year); (3) analyze the causes of identified risks; (4) implement measures to correct identified issues; and (5) evaluate the results of the work. 50 employees; may apply to employers with at least 20 employees if requested by employee representatives Annual but only need to analyze pay equity every other year
Spain All employers are required to develop wage registries showing average pay levels disaggregated by gender and, in addition, one of three options: (1) professional group and/or category, defined by collective bargaining agreement in most cases; (2) equal jobs, i.e., job title, functions; or (3) work of equal value, as defined in the new decree. Employers with at least 50 employees must provide an explanation in the wage registry of any pay gaps of 25% or higher. Moreover, employers with 50 or more employees must develop an Equality Plan that includes a wide variety of topics (hiring, promtions, working conditions, fair pay, prevention of harassment and other topics). 1 employee (wage registry only); 50 employees (Equality Plan) Wage registry must be updated annually; Equality Plan must be updated at least every four years (but may be more frequent)
Switzerland Organizations with at least 100 employees (not counting apprentices) must complete a statistically viable pay equity review. This review must be audited by an independent body and results of the review are to be shared in writing with employees within a year of completion. For those listed on the stock exchange, results must be included in the annex of the annual report. 100 employees First analysis to be completed no later than 30 June 2021; subsequent analyses must be re-run every 4 years
United Kingdom Employers must calculate, report and publish these gender pay gap figures: (1) percentage of men and women in each hourly pay quarter; (2) mean and median gender pay gap using hourly pay; (3) percentage of men and women receiving bonus pay; and (4) mean and median gender pay gap using bonus pay. 250 employees Annually by April 4 (deadline was extended in 2021 due to COVID)
United States There is no federal pay reporting requirement. There are two states — California and Illinois — that require pay reporting. 100 employees, and at least 1 California employee (California law); 100 Illinois employees (Illinois law) "Annual, 31 March (California law); Every two years (first deadline is rolling from 25 May 2022 and 23 March 2024 (Illinois law) "

 

How multinational brands are approaching pay equity

How can global companies ensure their approach to pay equity is globally consistent, while remaining responsive to local market practices? 

Companies should first have a global pay equity strategy. It is important to eliminate disparities to help create a culture of fairness in your organization. Companies take a mix of approaches to their overall global pay equity strategy. Some undertake multiple country-by-country analyses; others also look at their workforce globally or in cross-country groupings or regional analyses to evaluate consistency across the globe or within a region. 

Syndio’s Workplace Equity Platform and Expert Advisors help companies approach global pay equity in a way that can accommodate both within- and between-country analyses. We also see some companies start small — prioritizing countries with the most active pay equity legislation and where they have the most employees — then scale their program over time as they refine their processes. 

You also need a global pay reporting strategy. Syndio helps our customers analyze and complete pay reports for compliance with many pay reporting requirements around the globe. Have 250 employees in the UK? Syndio can help! How about reporting obligations in Switzerland? Or Spain? Germany? France? Syndio can help there, too! Syndio’s Expert Advisors actively track and support many global analyses, either within the Syndio platform or provided offline as a custom report run by our team.

And don’t stop there. As pay reporting laws continue to expand and put the spotlight on pay, it’s important to be prepared for questions from employees, investors, and other stakeholders. To help you build a communications strategy for your pay programs and reporting, check out our bundle of workplace equity communications resources linked below, including a step-by-step playbook, a lookbook featuring real-world communications examples from 20+ companies, and 5 tips from a leading communications consultant.

 

 

This Cheat Sheet is a quick guide about local reporting requirements in 15 key jurisdictions, but always consult with your counsel about how to ensure compliance. Syndio does not provide legal advice or guidance. All information, content, and materials are provided for general informational purposes only. Links to third-party or government websites are offered for the convenience of the reader; Syndio is not responsible for the content on linked pages.
Return to blog