Reporting data related to pay transparency

Who to include in the number of employees in the company?

Include all employees who work in the service of your company.

The place of work is not relevant. Also include employees posted abroad.

If a Finnish company has a permanent establishment in another country, do not include the employees employed there if their wage or salary is paid in accordance with the regulations of the country concerned. Similarly, data related to pay transparency does not need to be reported on these employees.

You can exclude the employees performing temporary or short-term seasonal work. These include summer employees, trainees and other seasonal or peak-period help.

If your company belongs to a group of companies, only include the employees of your company. Do not add up the total number of employees in the group.

Are persons receiving meeting fees or non-wage compensation for work included in the number of personnel?

They are not included.

Only include in the number of employees the persons who are employed in your company as employees. Do not include external individuals to whom you pay meeting fees or non-wage compensation for work, for example.

What is the date according to which to assess the number of employees in the company?

The number of employees is not assessed based on the situation on a particular date.

Examine the number of employees during the entire calendar year. The requirement to submit a report arises in the calendar year in which the number of employees first exceeds the limit of application of the Act for most of the year. In practice, this means at least nine months.

The employer’s separate report is also reviewed on an annual basis. Therefore, the decisive factor is not the number of employees on a given date or at the end of the year, but the situation throughout the year.

What does it mean that a company has employees employed on a regular basis during the calendar year?

This has been interpreted as meaning that the number of employees in the company exceeds the application limit during at least nine months of the year.

If the number of employees varies on both sides of the application limit, the employer should anticipate that the requirement to submit reports may apply to them and voluntarily report the required data using the earnings payment report.

Regardless of whether you are subject to the reporting requirement or not, as an employer, you should report the data to the Incomes Register as comprehensively as possible. This way, the users of the data will retrieve the data directly from the Incomes Register and not request it from you separately. 

How is a category of employees determined?

The employer determines how many different categories of employees the company has.

A category of employees means employees performing the same work or work of equal value. Grouping into categories must be based on non-discriminatory, objective and gender-neutral criteria. In other words, you cannot make up categories in an arbitrary manner.

Identify work of equal value using an assessment method in accordance with a collective agreement or another method. The aim is to group employees according to them having work tasks that are comparable in terms of their requirement level.
 
Consider the following criteria in the assessment

• competence required in the work
• amount of responsibility
• workload
• working conditions
• other factors relevant to the task.

Not all factors need to be emphasised in the same way. Which factors are the most important depends on the task.

The assessment compares the work tasks, not the employees. The objective is not to assess the competence or performance of an individual employee.

If the assessment of the requirement level of work is part of the pay system in a collective agreement, you can use the same assessment criteria when grouping employees into categories. In this case, employees performing the same work or work of equal value according to the criteria of the collective agreement belong to the same category of employees.

Can I use the assessment criteria of the collective agreement when grouping employees into categories?

Yes, you can.

If the criteria for assessing the work requirements have been agreed upon in the collective agreement binding on the employer, you can use them for grouping employees into categories.

The assessment criteria must be non-discriminatory, objective and gender neutral.

How do I report pay gaps if there is only one employee in the category of employees?

Report that only one gender is represented in the category.

Do not report a pay gap. 

Should the pay gaps be reported if there is only one employee representing the other gender in the category?

Yes, they should.

Report the pay gaps using the employer's separate report also when there is only one employee representing the other gender in the category and their wage could be deduced from the reported data.

The data is only available to the Ombudsman for Equality. We do not disclose them to other users of the Incomes Register data.

Can a employee belong to several categories of employees?

No, they can't.

A employee can only belong to one category at a time.

Some employees performing the same work receive a higher pay due to a merger. Do they belong to the same or different categories of employees?

Usually to the same.

If employees perform the same work or work of equal value and their work requirements regarded as a whole are similar, they belong to the same category of employees. A mere pay gap does not mean that employees belong to different categories.

Why are pay gaps reported separately as hourly and annual earnings?

Hourly and annual earnings data complement each other.

When you report the data separately as hourly and annual earnings, the gender pay gaps can be compared and assessed in more detail.

Can I get a report from the Incomes Register that I can use to report pay gaps?

We do not provide a report that would allow you to see data per category of employees. You must form the categories of employees yourself and calculate the gender pay gaps.

Do I report pay gaps in accordance with paid or full working hours?

Calculate the pay gaps based on the wage or salary actually paid. Report the data separately in hourly and annual earnings.

Which wage items are reported as basic wage, complementary items and variable items?

A basic wage is the fixed minimum wage or salary paid to the employee, which is paid for regular working hours without any compensations. It can be, for example, a time-rate pay, commission or contract pay.

Complementary items are wage items paid in addition to the basic wage, the amount of which usually remains the same from one wage to another. These include holiday bonus, company-paid telephone, housing allowance, etc.

Variable items are wage items the amount of which varies. These include overtime compensations, evening and night work compensations, stand-by compensations and bonuses.

If the company does not pay complementary or variable items, the related pay gaps do not need to be reported. However, always report the pay gaps based on basic wage.

How is the individual pay item reported?

The individual pay item is reported either as a variable or complementary item. The way it is reported depends on the income type used.

• If you report the pay item under income type 216 Other compensation, report it as a variable item.
•  If you report the pay item under income type 238 Other regular compensation, report it as a complementary item.

How are company-specific bonuses reported?

If the company-specific bonus is paid to the entire staff, report it as part of the basic wage.

If the bonus is only paid to a part of the staff, report it as a complementary item.

How is unjust enrichment taken into account in the reporting of pay gaps?

Unjust enrichment does not reduce pay when you calculate the gender pay gap.

Process the unjust enrichment according to the same income type as the original payment. For example, if unjust enrichment is related to basic wage, process it as basic wage.

Does recovery affect the gender pay gap?

Yes, it does. Recovery reduces pay when you calculate the gender pay gap.

Process the recovered amount according to the same income type as the original payment. If the recovery concerns, for example, the basic wage or complementary items, subtract the amount from the item in question.