France Releases Decree on Annual Pay Gap Reporting

In September, 2018, France enacted a law to address the gender pay gap. The law introduced new obligations for companies to report any pay gaps and all the steps taken to mitigate those gaps. Recently, the French government issued Decree 2019-15 outlining the methods to use to calculate and address the pay gap as well as providing additional guidelines for disclosure.

The decree specifies that the following indicators must be evaluated:

• The gender pay gap, calculated using  the average pay of women compared to men, by age group and equivalent job category
• The difference in the rate of individual increases (excluding promotion) between women and men
• The gap in promotion rates between women and men - only for companies with more than 250 employees
• The percentage of employees who returned from maternity leave during the reference pand who benefited from a pay increase upon their return during the same period
• Among the top ten paid employees, the number of women and men

The decree provides further detail on how to calculate the indicators, and methods for obtaining a score ranging from 0 to 100 points which must be published on the company website. Companies that fail to achieve a minimum score of 75 points will have three years to implement measures to increase their score to 75. Failing this, they will incur a financial penalty of up to 1% of the total payroll.

Companies must publish their results annually by March 1. The decree has provided longer transitional measures for smaller companies. Companies employing between 250 and 1000 employees will have until September 1, 2019 and those with 5-250 employees will have until March 1, 2020. Note that companies with more than 1000 employees must publish their results no later than March 1, 2019. 

By Vinaya Sakpal, Associate Consultant at DCI Consulting Group