Thousands Notices: Portugal’s Mandatory Pivot Toward Pay Transparency
With the end of voluntary pay equity in Portugal, legally binding enforcement by the ACT now requires companies to justify wage gaps with objective data, making proactive internal audits a strategic necessity for both regulatory compliance and organizational credibility.
BLOG
2/11/20262 min read
The era of “voluntary” pay equity in Portugal has effectively come to an end. In recent enforcement actions, the Autoridade para as Condições do Trabalho (ACT) has required thousands of companies to submit wage disparity assessment plans following the identification of gender pay gaps through the national Relatório Único reporting system (Autoridade para as Condições do Trabalho, 2024). These notifications are not advisory but legally binding, reflecting a data-driven approach to monitoring workplace equality.
Under Law No. 60/2018, employers must either justify identified pay disparities using objective, gender-neutral criteria or implement corrective measures within a legally defined compliance period. This represents a significant evolution in how the “Social” pillar of Corporate Social Responsibility (CSR) is assessed: organizational claims are now directly tested against administrative payroll data rather than voluntary disclosures.
For Portuguese managers, this regulatory shift functions as a precursor to the EU Pay Transparency Directive, which will further institutionalize pay transparency across the European Union. Moving toward compliance is therefore not solely about avoiding administrative sanctions, but about establishing organizational credibility in an increasingly transparency-driven labour market. Proactive measures, such as internal pay audits, structured salary frameworks, and transparent compensation policies, enable firms to mitigate regulatory risk while strengthening their employer brand and commitment to equitable workplace practices.
Reference
Autoridade para as Condições do Trabalho. (2024). Gender pay gap monitoring and enforcement reports. https://www.act.gov.pt/
Law No. 60/2018. (2018). Legal framework for equal pay between women and men. Diário da República.
EU Pay Transparency Directive. (2023). Pay transparency and equal pay directive. https://eur-lex.europa.eu/
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