Reviewing and mapping of pay conditions

As part of the activity and reporting obligation, Norwegian employers are required to review pay conditions every two years.  How should this be done?

Every second year, Norwegian employers are required to review the pay conditions by reference to gender, and publish the result of the mapping in the annual report. This is part of the enhanced activity and reporting duty in the Equality and Anti-Discrimination Act of 1 January 2020, known as the "equal pay mapping". Companies must complete the review for the first time for the financial year 2021. If the equal pay mapping reveals a pay gap between gender, the employer must identify the cause and consider measures to avoid gender-based pay gap.

How the mapping is done

The purpose of the mapping of pay conditions; the method of use; and how the figures are to be presented in the annual report, is defined by law.

The most important things to be aware of in the process are:

• All employees in the company must be included
• The wage concept includes both fixed pay and various wage supplements
• Employees shall be grouped by equal work and work of equal value
• The report of the review must make the average salary divided by men and women in each position group visible
• The work on the equal pay mapping must take place in collaboration with representatives of the employees – in practice, this often means elected representatives.

The purpose of the equal pay mapping is to contribute to more transparency of pay conditions by reference to gender and uncover gender pay gap. The legal requirement of the equal pay mapping includes an obligation of internal documentation of the process, and results. It also includes results published in the annual report. The internal documentation must provide employees with the opportunity to compare their salary against the average in their position group.

What must be included in the public report?

It is sufficient to state women's share of men's pay in each category, i.e., the results of the survey. For those employers who wish, it is possible to state the average salary in numbers. If stating the salary in numbers, the employers must take adequate privacy considerations into account.

Which employers need to perform a pay survey?

The employers that are covered by the four-step working method from section 26 in the Equality and non-discrimination Act, must perform equal pay mapping every second year, and at the same time publish the results in their annual report or other public document. 

How EY can help you

The work on the equal pay mapping is extensive and complicated due to the fact that the assessment applies not only to equal pay for equal work, but also to equal pay for work of equal value.  EY has a high level of expertise and experience with the activity and reporting obligations (ARP) – included equal pay mapping – and can assist in this work.