Employers in France face increased gender equality index disclosure requirements under Decree No. 2021-265 published on 10 Mar 2021. The changes modify provisions included in Decree No. 2019-15, which require employers with more than 250 employees to calculate their gender pay score using five indicators, and companies with between 50 and 250 employees to use four indicators. Employers scoring fewer than 75 out of 100 points have to publish the corrective measures taken, and report on their progress. Under the new decree, employers will have to publish — on their website — their overall gender pay equality index score as well as their scores for each gender pay indicator.

Employers have until 1 May 2021 to publish the overall score (calculated on 2020 data) in a visible and legible matter, and until 1 Jun 2021 to publish their scores for each gender pay equality indicator. The scores must remain on the company’s website until the next year’s scores are published. In addition, companies scoring fewer than 75 points must ensure that information on the corrective measures implemented, and the progress achieved, can be viewed on the company’s website until the company scores at least 75 points.

For 2022, companies will have to publish their scores by 1 Mar 2022 (calculated on 2021 data). Companies scoring fewer than 75 points have until 1 May 2022 to publish their objectives and improvement measures.

Related resources

Non-Mercer resources

• Decree No. 2021-265 of 10 Mar 2021 (French) (Legifrance, 11 Mar 2021)
• Decree No. 2019-15 of 8 Jan 2019 (French) (Legifrance, 9 Jan 2019)

Mercer Law & Policy resource

• French decree details gender pay methodology (8 Feb 2019)