1. Can pay transparency policies close the gender wage gap?

Valerie Frey

Many factors drive the wage gap between women and men, but there are few straightforward solutions to close it. Closing gender gaps in educational attainment have helped, but not enough. The same is true for family supports, like public childcare and paid leave, which have helped boost women’s labour force participation over the past few decades. Efforts to reduce horizontal and vertical segregation (Box 1.1) and attempts to equalise the gendered distribution of unpaid care work have moved at a glacial pace in most countries. Equal pay laws and anti-discrimination laws have been crucial for ensuring workers’ rights and exist widely throughout the OECD, but in practice these laws put the onus of equal pay on individual workers and do little to close gender wage gaps more broadly.

It is no wonder, then, that a sizeable gender wage gap persists in every OECD country, with rates ranging from around 4% to over 30% when looking at median full-time earners (Figure 1.1). These aggregate gender pay gaps likely underestimate the extent of the gender pay gap across different groups, as there are compounding, intersecting forms of discrimination based on different background factors like race/ethnicity, gender identity and sexual orientation. About half of the governments in the OECD say that women being paid less than men for the same work is one of the top three gender inequality challenges facing their country (OECD, 2017[1]).

Pay transparency and wage mapping measures are gaining momentum among governments trying to close the gender wage gap. Pay transparency measures are viewed as particularly important for addressing the discriminatory wage gap, i.e. the part of the gender wage gap that cannot be attributed to observable worker characteristics like level and field of education (Hofman et al., 2020[2]; European Commission, 2020[3]).

Eighteen out of the 38 OECD countries mandate systematic, regular gender wage gap reporting by private sector firms. Within this group, nine implemented comprehensive equal pay auditing processes, which require additional gender data analysis and typically propose follow-up strategies to address inequalities (Figure 1.1). Most of these policies were introduced in the past decade, and most of this movement took place in Europe. Many of these pay reporting rules cover the public sector, as well.

Just under half of OECD countries use job classification systems in the public and/or private sector, which attempt to standardise pay and make it transparent across men and women within specific job categories. These are more common in the public sector. Ten countries mandate that job classification systems, when they are used, be gender neutral. This is an attempt to correct for gender biases in job valuations that can exacerbate pay disparities. Gender-neutral job classification systems are often embedded within equal pay auditing processes, suggesting they may become more widespread if pay auditing policies gain momentum.

Because most pay transparency policies are relatively new, there has been limited research carried out evaluating their effects on wage and employment outcomes. The available research on national pay transparency rules has largely concentrated on company pay reporting obligations.1

Studies of company pay reporting rules have typically found small reductions in the gender wage gap when reporting measures are accompanied by the threat of sanctions and/or relatively high policy visibility, as is the case in Denmark (Bennedsen et al., 2019[4]) and the United Kingdom (Blundell, 2021[5]). The positive effects arise through a reduction in men’s wages, rather than an increase in women’s wages. Where enforcement mechanisms or wage gap visibility are weaker, however, these measures seem to have had fewer positive effects (Böheim and Gust, 2021[6]; Gulyas, Seitz and Sinha, 2020[7]).

Studies looking at smaller, targeted populations of workers, such as university faculty in Canada and the United States, have also found that publishing salaries helps to close the gender wage gap (Baker et al., 2019[8]; Obloj and Zenger, 2020[9]).

Pay transparency policies should continue to be evaluated in different contexts to see how features of different systems may affect gender wage gaps in different ways. Given that pay transparency policies are often phased in with rules based on firm size, these policies are ripe for rigorous, quasi-experimental evaluations with nearly comparable “treatment” and “control” groups around the policy threshold.

Although the evidence base is still being built, pay transparency policies hold significant appeal. Pay transparency measures represent a relatively simple, intuitive tool both to identify and to take action against the gender wage gap in the workplace – particularly in mid-sized and larger organisations with dedicated human resources management that can calculate gender gaps.

Crucially, pay transparency policies give workers, employers and the public an important tool to combat gender inequality: they offer an acknowledgement of the existence and the size of gender pay gaps.

This report takes stock of the policies, laws and regulations around pay transparency and wage mapping across the 38 OECD member countries. The report explores:

  • Countries’ efforts to define the concept of “work of equal value” and gender-neutral job classification systems (Chapter 2);

  • Company pay reporting requirements (Chapter 3);

  • Equal pay auditing requirements (Chapter 4);

  • The role of social partners and collective bargaining in equal pay (Chapter 5).

Each of these policies, defined in Box 1.1, have strong potential to narrow the gender wage gap. But strengthening reforms, greater stakeholder engagement, and more and better evaluations are needed.

The OECD average gender wage gap stands at 12.8% – meaning that a woman working full-time today makes 87 cents, on average, for every dollar or euro a full-time working man makes at median earnings (Figure 1.1) The gap gets even larger when looking at the average pay all working women and men take home at the end of the year, because women tend to spend fewer hours in paid work than men do. Women are overrepresented in part-time jobs, and underrepresented in jobs with long work hours, throughout the OECD (OECD, 2017[11]; 2019[12]).

The widest gender pay gaps are in the two East Asian OECD countries (Japan and Korea) and Israel. In some countries – such as Greece, Italy and Turkey – small gender pay gaps are the result of selection effects reflecting the relatively small number of women who participate in the labour market. These countries have comparatively lower female labour force participation, but their more highly educated (and higher-earning) female workers tend to remain in the official labour force, thereby inflating female median earnings (OECD Family Database, 2021[13]).

This gender pay gap of 12.8% is an improvement from the gap of nearly 19% in 1996, when most OECD countries began reporting this statistic (Figure 1.3). Nevertheless it still represents a remarkable gender inequality, particularly among high earners (see Box 1.2).

Many factors drive the gender wage gap. One issue is horizontal segregation, meaning that men and women are concentrated in specific sectors or jobs. Women tend to be overrepresented in fields that pay relatively lower wages, such as caregiving and service sector jobs, and underrepresented in fields with relatively higher wages, such as science and technology jobs.

Vertical segregation, meaning that men and women are concentrated in different job levels, also affects women’s pay. Women’s career progression is often limited, particularly in those sectors with fewer women, and across OECD countries women are underrepresented in management roles (OECD Gender Data Portal, 2021[14]).

Another major barrier is the enormous inequality that exists in the distribution of unpaid work hours (OECD Gender Data Portal, 2021[14]). Women do much more cooking, cleaning, looking after the elderly, and childcare than men, which, in turn, limits both the time women can spend in paid work and their possibilities to advance in the paid labour market (OECD, 2021[15]; 2017[11]; 2017[16]). This has negative implications for their pay, particularly in jobs with inflexible work hours (Goldin, 2014[17]).

Importantly, discrimination negatively affects women’s pay. This has been proven through randomised field experiments. In these types of studies, researchers generally create fictitious job candidates applying for jobs, by correspondence, with exactly the same applicant credentials except for the gender of the applicant. These studies have found discrimination against women both in the hiring process for higher-paid jobs and in the starting salaries that are offered. (For a summary of this literature, see (Blau and Kahn, 2016[18])). This almost certainly has downstream effects on the gender wage gap over the life course.

This longstanding gender wage gap is a global injustice. Aside from the economic imperatives of gender equality in labour markets (OECD, 2017[1]; World Bank, 2018[19]), there are even more important implications for human rights and social justice. Women’s economic empowerment has obvious positive consequences for women’s agency, freedom, and social and political empowerment.

Unequal wages during the working years have long and compounding effects on gender inequality throughout the life course. Lower earnings lessen women’s economic independence throughout life, but the consequences are painfully obvious in old age.

There is a sizeable gender gap in retirement income, wealth and pensions that arises after a lifetime of unequal earnings across OECD countries. Women aged 65 and older receive only around three-quarters of the retirement income of men from public and private pension arrangements on average in the OECD (OECD, 2021[20]; 2019[21]). Related to this (and to women’s longer life expectancy), nearly every OECD country2 has higher poverty rates for women than men. The average old-age poverty rate for women in OECD countries is 15.7%, while for men it is 10.3% (OECD, 2019[21]).

Women’s earnings are important at the household level, as well. During childrearing years, mothers’ equal participation in the labour market is essential for both raising overall family income and for ensuring a more equal distribution of (paid and unpaid) resources at home. Additionally, it is now almost conventional wisdom in economics that children do better in areas like health when their mothers control a larger share of household resources. This control over spending is influenced (though obviously not entirely) by who brings the income into the home (OECD, 2019[12]).

Closing the gender wage gap depends crucially on knowing whether, how, and to what extent such gaps exist. At the aggregate level – within a workplace, town, region, country, and so on – administrative data and labour force statistics can help researchers and governments identify when gender wage gaps occur and what might be driving them.

So-called observable factors driving the gender wage gap include an employee’s age, level of education, field of study, sector of employment, workplace, parenthood status, and other variables (OECD, 2017[1]). Recent research using match employer-employee data suggests that nearly 80% of the gender wage gap, across a sample of 16 OECD countries, is attributable to pay inequity within firms, (OECD, 2021[23]).

It is very difficult, however, for an individual worker to know whether she or he is being underpaid – and with whom their salary should be compared. Very few countries guarantee workers the right to learn a specific colleague’s (or small group of colleagues’) pay (Box 1.4).

Many countries identify privacy and data protections as a hurdle to sharing a specific, comparable colleague’s pay (OECD GPTQ 2021). Logistical or operational barriers are another issue; as with other transparency requirements, some companies claim that identifying and sharing the salary of a “comparator” is too high an administrative burden (OECD GPTQ 2021), though it is not clear that doing so would be much more difficult than other forms of pay reporting.

Furthermore, the issue of finding either a hypothetical comparator or an accurate, real-life comparator has been a longstanding challenge across countries (European Commission, 2020[3]). In short, who should qualify as a comparable colleague for the basis of a pay comparison?

Countries have used different approaches to address the comparator issue. Such approaches include legislation allowing the comparison of salary with the previous person who held a post, allowing comparison with a group of colleagues, requiring that the comparator be of an opposite sex, and/or requiring that the comparator be employed within the same company (European Commission, 2020[3]) (OECD GPTQ 2021). New Zealand, notably, has recognised that the historic undervaluation of traditionally women’s work necessitates a comparator being sourced from a different sector. Some other countries have said that a comparator should not be necessary at all to prove unfair pay.

In sum, the comparator question remains a difficult, practical puzzle to solve when pay discrimination cases arise.

It must be emphasised that gender wage gaps represent a much broader problem, in both societies and labour markets, which cannot be fixed individually.

When armed with the knowledge that they have been underpaid, a worker tends to have a limited number of options: do nothing, negotiate higher pay, or initiate a pay equity claim. In all three instances the onus of identifying, raising, and rectifying (possibly discriminatory) pay inequity rests on the individual, which is a very large burden.

While pay transparency laws may give workers more information, their effectiveness largely relies upon workers having bargaining power to negotiate collectively or individually – and to negotiate without backlash, which is less likely the case for female workers. Research shows that women tend to be less likely than men to negotiate for a higher salary, and when they do negotiate they tend to face backlash, or a “social penalty” (Bowles, 2014[24]).

This means that even if a female worker correctly identifies a pay equity issue, raising it with her employer may not be an easy step or a feasible solution. Additionally, pay equity claims that go through the legal system tend to be costly, both in time and money.

Nevertheless, legal mechanisms must be in place for either an individual or a group of workers to seek recourse if they are indeed underpaid for doing work of equal value to a colleague or workers supplying work of equal value. To support this, objective criteria to assess work of equal value should be used for pay equity claims. Access to justice should be streamlined and the burden of proof in pay discrimination cases should rest on the respondent (European Commission, 2020[3]).

Governments in OECD countries have begun innovating fairly recently with systemic pay transparency policies. In many countries with pay auditing or pay reporting requirements, these rules only went into effect over the past decade. This represents an important, relatively rapid, and large-scale shift to address pay inequality across OECD countries.

All of these pay transparency measures can function at least as well as a right to request a comparator’s pay – but only if they are designed and implemented well.

Many pay transparency policies have been only recently introduced and need more systemic evaluation, but some policy conclusions have become apparent across countries. Other approaches are less frequently used but show promise.

  • Ensuring buy-in from different actors is important for ensuring compliance and take-up of pay gap reporting and equal pay auditing.

    OECD governments frequently point to the low quality of employers’ reported wage gap statistics as a problem. Generating buy-in from stakeholders has the potential to help improve the quality of reporting and, when applicable, follow-up actions. Countries that include multiple actors in pay reporting typically involve workers, social partners and the government. Countries like Sweden, Finland, and France involve unions or works councils extensively in the pay auditing process (Chapter 4), for instance, and these actors function as agents of workers at that stage, even if they are not always required to consider the gender wage gap during salary negotiations (see Chapter 5).

    Worker and public awareness of pay reporting results can also help drive support for pay equity (Box 1.5), as in practice pay gap reporting rules are often not well known.

  • Wage gap reporting should have clear guidelines and straightforward processes.

    Governments can help simplify the process of wage gap reporting by giving employers clear and direct definitions of what statistics must be reported. Digital tools, too, can help companies calculate wage gaps. This is important given that administrative burden is a frequently cited concern raised by countries encountering pushback from companies (OECD GPTQ 2021) (European Commission, 2017[26]), though recent research suggests that the actual pay reporting cost to companies averages well under EUR 1 000 annually (Eurofound, 2020[27]).3

    France offers an example of a country with an extensive but straightforward list of wage statistics4 required for an audit (Chapter 4), and countries like Canada, Israel, Portugal, France and Switzerland have developed publicly available official calculators to help companies meet pay reporting requirements. The Swiss “Logib” tool,5 for example, usefully offers two modules for companies of different sizes to self-assess their gender wage gap.

  • The type of data reported matters.

    Governments must consider the advantages and disadvantages of different wage gap statistics required in reporting. Some countries ask for one or two simple data points – like the wage gap at the mean and median – while others ask for an extensive list of gender-disaggregated statistics on wage and employment outcomes across different jobs.

    There are benefits and drawbacks to each approach. Reporting the overall gender wage gap within firms, i.e. without separating workers by job, could encourage firms to train and promote women across occupations – and it may be easier for companies (particularly smaller firms) to calculate an overall gap with existing human resources staff, rather than having to outsource the analysis. It may also give workers a global perspective on how their employer treats women and men in the workplace. However, such a basic measure may conceal inequalities (and possibly discrimination) across workers in the same job. It also may not sufficiently support pay equity claims that require a comparator.

    In comparison, reporting the gender wage gap by subgroups like occupation, skills or experience would better reveal inequalities across similar men and women.6 However, this has a larger administrative burden and may discourage proactive equality policies if differences are small, or even prevent firms from acting against parts of the gender wage gap that can be explained by observable characteristics.

    To achieve pay equity goals, it is perhaps most effective for companies to calculate both sets of statistics, with the overall wage gap easily estimated based upon the disaggregated measures.

    Variables beyond pay statistics may also be relevant as part of gender audits. For example, France requires companies to report how many women returning from maternity leave received regular step increases in pay, and countries like Germany, Korea and the United States mandate gender-disaggregated employer reporting on employee statistics other than pay, such as the gender composition of the workforce (Chapter 4).

  • Enforcement and penalties carried out by a dedicated government actor can help ensure compliance, though different enforcement strategies seem to be working well in different places. In the United Kingdom, for example, the “name and shame” approach – in which a company’s overall gender pay gap or failure to report is published online for public consumption – has likely contributed to 100% reporting compliance in the first two years of the programme.

    The French auditing system has teeth in the form of inspections by the Ministry of Labour, Employment and Inclusion, which reports a consistent improvement in compliance since the latest auditing process went into effect in 2019. Italy relies on its dedicated regional Gender Equality Advisors, who work with the Labour Inspectorate to monitor compliance. In Iceland, companies’ pay equity outcomes are monitored by government-regulated auditors; this is also typically the case in Switzerland.7 In a novel strategy, Lithuania recently tasked its social insurance agency to begin publishing companies’ wage gap statistics based on administrative data.

    Countries without a dedicated government actor regularly enforcing reporting requirements tend to have less data on compliance, so it is unclear how effective their measures are. In many countries, companies’ failure to comply adequately can be followed by financial sanctions.

  • Action plans should be developed to address gender gaps that are found. Complying with reporting obligations, in the form of identifying and reporting wage gaps, is a crucial first step. Yet reporting will do little to reduce pay inequity without a relevant, tailored plan created by firms to address such gaps. This needs to be matched with government or union enforcement of the content of action plans, within a reasonable timeframe, to help ensure pay transparency measures can actually reduce the gender pay gap. Otherwise the gaps that are found may be ignored or left to workers and their representatives to address.

  • Job classification systems can offer a straightforward way to present workers’ pay across jobs. Job classifications can be used not only to address gender gaps but also other forms of discrimination among workers, as pay is defined for the job regardless of who carries it out. They also can help facilitate calculations as part of pay reporting and auditing processes, and can help in pay equity cases – though they do little to reduce gender wage gaps caused by horizontal segregation. When job classification systems are designed with intentional equal pay considerations, they are more likely to achieve equal pay for work of equal value goals (Chapter 2).

  • Legislation around the concept of equal pay for work of equal value, rather than the simple concept of equal pay for equal work (i.e. the same or very similar job), can help to correct for the historical undervaluation of jobs and sectors that have typically been considered “women’s work”.

    New Zealand is systematically advancing this approach,8 and it has also been supported in case law in places like Spain (Chapter 2). As part of its comprehensive auditing process, Iceland requires the analysis of pay gaps both for the same work and for work of equal value. However, the onus tends to remain on workers or their representatives to initiate pay equity claims, which are typically costly and time-intensive.

  • Improve the quality of reporting. There are significant quality differences in companies’ reporting both within and across countries. Even countries with relatively advanced and longstanding auditing systems – such as Finland and Sweden – report that some companies are doing the bare minimum to meet reporting requirements, let alone advance an action plan to combat their firm’s gender wage gap.

    Improving the quality of reports likely requires the participation of a dedicated government actor with regular oversight responsibilities. Governments should increase the minimum standards needed to comply with the content of reporting obligations.

  • Increase the share of firms that are covered by reporting requirements. Most countries that mandate reporting require it for companies with a minimum of between 30 and 500 employees.9 Consequently, a large portion of the labour force is not covered by pay transparency rules – thereby limiting the effectiveness of such policies on the overall gender wage gap.

    Countries tend to include carve-outs for smaller firms in an effort to reduce their administrative burden. However, as explained above, pay reporting is relatively low cost, particularly if governments provide an online pay gap calculator.

  • Carry out more – and more rigorous – evaluations of wage outcomes. Countries with pay transparency rules have not conducted rigorous evaluations of policy effects on pay outcomes. This makes it difficult for governments to determine whether current pay transparency laws are achieving their stated gender equity goals.

    Academic research, when available, has found that pay transparency has slightly reduced the gender wage gap in countries with adequate enforcement and/or policy visibility.

    When it is not possible to implement randomised experiments during programme implementation or reform, government research offices and academics should consider using quasi-experimental methods to evaluate pay transparency programme effects. This might entail, for example, exploiting discontinuities in outcomes between employers who are barely above a reporting requirement threshold with employers who are barely below a reporting requirement threshold, as has been done in academic research on Austria, Denmark and the United Kingdom (Chapter 3).

  • Increase and improve evaluations of policy processes, including the collection of compliance data. A number of countries do not actively keep track of whether firms are fulfilling pay transparency obligations. While many countries may have penalties for firm non-compliance, in many instances it can be unclear whether these penalties are enforced or sufficient to act as a deterrent. For instance, most countries were unable to provide data on how often pay transparency measures had been enforced (OECD GPTQ 2021).

  • Raise awareness of pay transparency initiatives among social partners, employees, employers and the public during policy design and delivery. While some countries conduct awareness-raising and training campaigns, a more comprehensive approach that targets all affected actors, at different stages of policy design, will help ensure policy measures are effective (Box 1.5).

  • Increase the use of intentionally gender-neutral job classification systems. There is considerable variation across OECD countries in the use and mandating of gender-neutral job classifications systems. Even if gender-neutral job classifications are not mandated, governments can help make them more widespread. For instance, in Lithuania, the government has worked with stakeholders to establish guidelines on how companies can create a gender-neutral job classification scheme.

  • Ensuring, where appropriate, that equal pay is mandated in collective bargaining. This could take place at the sectoral or workplace level. Whether mandating equal pay discussions during collective bargaining is necessary may depend upon worker bargaining power and the role and coverage of unions. For instance, Sweden reports that with high union coverage and a strong union role in promoting gender equality, mandating such a measure is not necessary. Regardless, ensuring that collective agreements cannot contravene existing equal pay or anti-discrimination laws is a necessary measure.

  • Reducing barriers to a successful equal pay claim. Equal pay cases tend to be relatively infrequent, and, when initiated, workers and their representatives tend to experience costly (both in time and money) legal proceedings. Countries should make use of alternative dispute resolution mechanisms and make the comparator easier to identify in equal pay claims. They should also move the onus to disprove discrimination from workers to the employer, as is being considered in Luxembourg.

  • Promote convergence in pay transparency commitments across OECD countries. Some countries, particularly in Europe, have initiated a range of pay transparency policies, while other countries have barely moved beyond basic equal pay legislation. A goal of this report is to share lessons learned, so that countries with a less developed approach to the gender wage gap may be encouraged to take a step in the direction of pay transparency, in line with national priorities, abilities and constraints.

  • Embed pay transparency within a broader public commitment to gender equality and closing the gender wage gap.

    In many ways, pay transparency policies come too late – they seek to remedy wage gaps after years of gendered socialisation, gendered schooling, and gendered labour market decisions have occurred.

    Governments must take a holistic, multifaceted approach to ending gender inequalities, from a very young age, at home, in society, and in labour markets. Such an approach will significantly lessen the need for pay transparency measures to address what have often become deeply embedded inequalities during the working years.

This report covers the 38 member states of the OECD, spanning from North and South America to Europe and Asia-Pacific (https://www.oecd.org/about/members-and-partners/).

In February 2021, the OECD distributed a detailed policy questionnaire (see Annex A) via the Employment, Labour and Social Affairs Committee (ELSAC) to gender, labour, and/or social ministries in every OECD country in order to take stock of gender wage mapping and pay transparency measures aimed at promoting equal pay between women and men.

The response rate was 100%, with 38 member states either completing the questionnaire in full or validating missing responses. The questionnaire requested details on the following public strategies for promoting equal pay in each country:

  • Right of employees to request information on pay levels

  • Regular reporting by companies on pay levels

  • Pay audits

  • The role of social partners and collective bargaining in equal pay

  • Gender-neutral job evaluation systems and defining the concept of “work of equal value”

  • Other pay transparency measures

  • Transparency measures led by social partners

  • Impact evaluations of measures to address equal pay

  • Other recent government policies to address explicitly the gender wage gap

The information collected for this report will also be used to fulfil the reporting requirements of 2013 OECD Recommendation of the Council on Gender Equality in Education, Employment and Entrepreneurship and the 2015 OECD Recommendation of the Council on Gender Equality in Public Life. Information was collected on both the private and the public sector to support these reporting requirements.

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[28] United Kingdom Government Equalities Office (2018), Presenting gender pay gap figures to the public: an online trial - GOV.UK, United Kingdom Government Equalities Office, https://www.gov.uk/government/publications/presenting-gender-pay-gap-figures-to-the-public-an-online-trial (accessed on 17 September 2021).

[19] World Bank (2018), Unrealized Potential: The High Cost of Gender Inequality in Earnings, https://doi.org/10.1596/29865.

Notes

← 1. Another study looks at state-level pay secrecy laws in the United States, which prohibit employees from sharing their wage information with others. Kim (2015) finds that the prohibition of pay secrecy rules corresponds with a lower gender wage gap, particularly among more highly-educated workers (Kim, 2015[32]).

← 2. An exception is Chile, where poverty risks are nearly equal between women and men.

← 3. This is a cost that could potentially be publicly subsidised for small employers.

← 4. Guidelines to the reporting requirements of France’s Professional Equality Index (PEI) between Women and Men (l’Index de l’égalité professionnelle entre les femmes et les hommes) are available at this site (in French): https://travail-emploi.gouv.fr/droit-du-travail/egalite-professionnelle-discrimination-et-harcelement/indexegapro

← 5. Switzerland’s Logib calculator is available at https://www.logib.admin.ch/home.

← 6. A recent survey of 124 employers and employee representatives in 14 countries found a preference for reporting the gender wage groups with more fine-grained details, e.g. for specific positions or tasks, rather than the aggregated gender wage gap for the entire organisation (Eurofound, 2020[27]).

← 7. In Switzerland, a pay equity audit can be carried out by an independent body that is not regulated by the government, i.e. an organization under Article 7 of the Gender Equality Act or an employees’ representation (see Article 13d para 1b Gender Equality Act (GEA)). These organizations under Article 7 GEA are not audit firms in the sense of the Auditor Oversight Act. However, in practice most audits will be carried out by firms of auditors licensed under the aforementioned Auditor Oversight Act. Only a minority of employers choose an organization under Article 7 GEA.

← 8. New Zealand is attempting to correct for historical pay discrimination by addressing remuneration gaps across male-dominated and female-dominated occupations that hold equal value. Since the Equal Pay Amendment Act of 2020, a new pay equity procedure allows unions, or individual employees, to raise pay equity claims on the basis that the work the claim relates to is predominantly performed by women, defined as 60 percent of the workforce being female, and is currently, or has historically been, undervalued. Once undervaluation has been established, the work can be compared with comparable work predominantly performed by men (Chapter 2).

← 9. A notable exception to this trend is Sweden, which requires equal pay audits from firms with at least ten employees.

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