France
Is there any existing legal requirement to report on any gender pay gap?
Yes, some companies are subject to an obligation to establish and publish a Gender Pay Gap Index.
If so, what are the requirement triggers?
All companies with at least 50 employees (over three consecutive years) must calculate and publish a Gender Pay Gap Index, which consists of 4 to 5 main criteria (depending on whether the company has more than 250 employees), i.e.:
- The gap between male and female average salaries calculated for similar age groups and job categories;
- The gap between male and female rate of salary increases (excluding promotion);
- The percentage of female employees receiving a salary increase after returning from maternity leave;
- The number of employees of the under-represented sex among the 10 highest paid employees;
- The gap between male and female promotion rates (only in companies with more than 250 employees).
In practice, a specific number of points (as provided under a Decree) is allocated to each indicator.
The total score (calculated on 100 points) obtained by the company corresponds to the sum of the points obtained for each indicator.
What frequency of reporting is required?
The Gender Pay Gap Index must be published annually, on 1 March each year at the latest, for the previous year.
Is the report required to be published externally?
Yes. The Gender Pay Gap Index results for each year are published on the company's external website (a publication on the intranet is not sufficient), or if there is no website, communicated to employees. The results must also be communicated to employee representative bodies via the Economic, Social and Environment Database (“BDESE”), and transmitted to the French Labour Inspectorate (DREETS) by electronic declaration on https://solen1.enquetes.social.gouv.fr/.
Is there a sanction for non-compliance with the duty to report?
Yes. Failure to publish the Gender Pay Gap Index or having a score of less than 75 points in the Index can be sanctioned by a penalty of up to 1% of the total of the employees’ wages.
Has France yet fully transposed the requirements of the Pay Transparency Directive? If yes, what was the implementation date and what is the name of the legislation?
No.
If the Pay Transparency Directive has not yet been transposed, what steps have been taken towards implementation?
The French Ministry of Labour has announced that multilateral consultations will now take place, with the aim being to finalise a text by September 2025 in order to transpose the Directive by the end of 2025. On 14 May 2025, French Labor Minister Astrid Panosyan-Bouvet confirmed changes to the current gender equality index in 2027 as part of the plan to transpose the Directive. Consultations with social partners began on 21 May 2025.
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