Belgium Equal Pay CBA No. 25

Overview

Collective Bargaining Agreement (CBA) No. 25, signed on 15 October 1975, represents a landmark piece of legislation in Belgium, establishing the principle of equal pay for male and female workers for the same work or work of equal value. This agreement, concluded within the National Labour Council (Conseil National du Travail - CNT) by interprofessional employer and worker organizations, was subsequently rendered obligatory by Royal Decree, granting it binding legal force across various sectors and enterprises in Belgium. Its primary purpose was to transpose international and European legal principles concerning equal remuneration into the national legal framework, thereby ensuring that Belgium adhered to its commitments under treaties such as the ILO Convention No. 100 and Article 119 (now 157) of the Treaty of Rome.

The historical context of CBA No. 25 is rooted in the growing international and European emphasis on gender equality in the workplace during the 1970s. Prior to its adoption, the principle of equal pay was already enshrined in international instruments like the ILO Convention No. 100 of 1951 and Article 119 of the Treaty establishing the European Economic Community (EEC) in 1957. However, a national, comprehensive legal instrument was needed to concretely implement these principles. CBA No. 25 filled this void, acting as a crucial national transposition mechanism, particularly in response to the Council Directive 75/117/EEC of 10 February 1975, which aimed at approximating Member States' laws on the application of the principle of equal pay. This made the CBA a pioneering instrument, setting a robust standard for pay equity in Belgium.

CBA No. 25 introduced several key innovations, most notably the explicit requirement for gender-neutral job evaluation and classification systems. It stipulated that remuneration systems must not lead to discrimination, neither through the choice or weighting of criteria nor through the conversion of job points into wage points. This focus on the underlying structures of pay determination was critical for addressing systemic gender bias. The agreement has been amended twice: by CCT No. 25bis on 19 December 2001 and CCT No. 25ter on 9 July 2008. These amendments primarily aimed to reactivate and strengthen the role of a specialized joint commission within the National Labour Council, providing technical assistance to social partners in developing and analyzing gender-neutral job evaluation systems. These modifications underscore the enduring relevance and adaptive nature of CBA No. 25 as a foundational document in Belgium's ongoing commitment to pay equity.

Definitions

Collective Bargaining Agreement No. 25 provides essential definitions to clarify the scope and application of the equal pay principle. Central to the agreement is the concept of “remuneration.” Article 4 of the CBA defines remuneration broadly, encompassing not only the basic salary but also all other benefits, whether in cash or in kind, that an employee receives directly or indirectly from their employer by reason of their employment. This expansive definition aligns with the interpretation provided by the Court of Justice of the European Communities (now the Court of Justice of the European Union), which has consistently held that remuneration includes any advantage paid by the employer, directly or indirectly, to the worker in respect of their employment. This comprehensive scope ensures that all components of an employee's compensation package are subject to the equal pay principle, preventing employers from circumventing the law by shifting discriminatory practices to non-basic pay elements.

Another crucial term defined and elaborated upon in CBA No. 25 is “equal work or work of equal value.” The agreement mandates equal remuneration for “the same work or work of equal value” (même travail ou travail de même valeur). This distinction is vital because it extends the principle beyond identical jobs to those that, while different in nature, hold equivalent value within the employer's organization. The determination of "work of equal value" is explicitly linked to objective criteria, particularly through job evaluation and classification systems. The CBA emphasizes that these systems must be gender-neutral, meaning they should not lead to discrimination based on sex, either through the selection of criteria, the weighting of those criteria, or the method of converting job points into wage points. This provision highlights the importance of systematic and unbiased assessment of job roles to ensure that traditional gender biases do not inadvertently perpetuate pay disparities.

The amendments to CBA No. 25, specifically CCT No. 25bis (2001) and CCT No. 25ter (2008), further elaborated on the concept of job evaluation. CCT No. 25bis recommended the analysis of all job classifications for gender neutrality, while CCT No. 25ter made this analysis compulsory for all joint committees. This evolution underscores a recognition that achieving equal pay for work of equal value necessitates a proactive and systematic approach to reviewing and, if necessary, reforming the tools used to assess and categorize jobs. By focusing on the neutrality of job evaluation systems, the CBA aims to eliminate subjective biases that might undervalue work predominantly performed by women, thereby ensuring that the principle of equal pay is applied in a truly equitable manner across diverse roles within an enterprise or sector.

Covered Employers

Collective Bargaining Agreement No. 25, once rendered obligatory by Royal Decree, applies broadly across all employers and workers within its scope, which is interprofessional and national. Unlike some later legislation that introduces specific size thresholds for certain reporting obligations, CBA No. 25 establishes a general principle of equal pay that is universally applicable. The agreement's text must be annexed to the work regulations (règlement de travail) of every company operating in Belgium. This requirement ensures that the provisions of CBA No. 25 are made known to all employees and employers, integrating the principle of equal pay directly into the operational rules of each workplace. The inclusion in work regulations signifies its fundamental nature as a core employment condition.

The broad application of CBA No. 25 means that it covers both private and public sector employers, without specific exemptions based on company size or sector, for the core principle of equal pay. The legal framework for Collective Bargaining Agreements in Belgium, established by the Law of 5 December 1968, allows for interprofessional agreements like CBA No. 25 to have a wide-ranging impact once declared universally binding by Royal Decree. This ensures a consistent standard for pay equity across the Belgian economy. While subsequent laws, such as the Act of 22 April 2012 on reducing the gender pay gap, introduced specific thresholds for reporting and audit obligations (e.g., companies with 50 or more employees), these later requirements build upon the foundational principle established by CBA No. 25, rather than limiting its scope.

The obligation to include CBA No. 25 in the company's work regulations is a critical aspect of its implementation. This ensures that the principle of equal pay is not merely an abstract legal concept but an integral part of the daily operational framework of every enterprise. The work regulations typically outline the rights and duties of both employers and employees, and by incorporating CBA No. 25, employers are explicitly reminded of their legal duty to ensure non-discriminatory pay practices. This broad coverage and the mandatory inclusion in work regulations underscore the significance of CBA No. 25 as a fundamental and enduring component of Belgian employment law concerning pay equity, setting the baseline for all subsequent legislative and regulatory developments in this area.

Employee Rights

Under Collective Bargaining Agreement No. 25, employees are granted several crucial rights aimed at upholding the principle of equal pay for equal work or work of equal value. The most fundamental right is the entitlement to receive remuneration without discrimination based on sex. This means that male and female workers performing the same job or a job deemed to be of equal value must receive equivalent pay and benefits. This right is directly enforceable, allowing employees to challenge any pay disparities they believe are discriminatory. The CBA's broad definition of "remuneration" ensures that this right extends to all components of compensation, including basic salary, bonuses, and benefits, preventing employers from using indirect means to perpetuate pay inequality.

Beyond the right to equal pay itself, CBA No. 25 provides significant protection for employees who seek to exercise this right. The agreement explicitly protects workers from dismissal or unilateral modification of their working conditions if such actions are taken in retaliation for filing a complaint or initiating legal action related to equal pay. This anti-retaliation provision is vital for encouraging employees to come forward without fear of adverse consequences. If an employee is dismissed or has their working conditions unilaterally altered for such unjustified reasons, they or their affiliated trade union can request reintegration into the company or reinstatement to their original position.

In cases where reintegration or reinstatement is refused by the employer, the employee is entitled to compensation. This compensation, at the employee's choice, can be either a lump sum equivalent to six months' gross remuneration or an amount equal to the actual damage suffered, provided the employee can prove the extent of that damage. This provision for substantial compensation serves as a deterrent against retaliatory actions and provides a meaningful remedy for affected workers. Furthermore, the CBA's requirement for gender-neutral job evaluation systems implicitly grants employees the right to expect that the criteria used to determine their pay are objective and free from gender bias, laying the groundwork for future transparency rights.

Pay Transparency Requirements

While Collective Bargaining Agreement No. 25 itself does not contain explicit provisions for pay transparency in the modern sense, such as mandatory salary range disclosures in job postings, it lays a crucial foundation for transparency through its emphasis on objective and gender-neutral job evaluation systems. The CBA mandates that job classification and evaluation systems must be designed and applied in a way that does not lead to discrimination based on sex, whether through the choice of criteria, their weighting, or the conversion of job points into wage points. This requirement inherently promotes a degree of transparency by necessitating a structured and justifiable approach to determining the value of work, which can then be scrutinized for potential biases. By requiring employers to base remuneration on objective job assessments, the CBA implicitly calls for a transparent methodology in pay determination.

The amendments to CBA No. 25 further reinforced this foundational aspect of transparency. CCT No. 25bis (2001) recommended, and CCT No. 25ter (2008) made compulsory, the analysis of all job classifications for gender neutrality by joint committees. This obligation means that the methodologies and criteria used to classify jobs and, by extension, to determine pay, must be open to review and justification. Although not direct "pay transparency" in terms of individual salary disclosure, this focus on the transparency of the process of job valuation is a critical precursor. It ensures that the underlying structures that dictate pay are not opaque or arbitrarily applied, thereby enabling a more equitable and understandable remuneration framework. This systematic review process, even if not directly accessible to individual employees in real-time, contributes to a broader culture of transparency in pay-setting mechanisms.

It is important to note that more explicit pay transparency requirements, such as disclosing salary ranges in job advertisements or providing employees with information on average pay for comparable roles, were introduced in Belgium by later legislation, notably the Act of 22 April 2012 on reducing the gender pay gap and the upcoming transposition of the EU Pay Transparency Directive (2023). CBA No. 25, however, established the essential principle that pay structures must be objectively justifiable and free from gender bias, thereby creating the necessary legal and conceptual groundwork upon which these later, more direct transparency measures could be built. The requirement to include the full text of CBA No. 25 in a company's work regulations also ensures that the fundamental principle of equal pay and the need for gender-neutral evaluation systems are transparently communicated to all employees.

Reporting & Audit Obligations

Collective Bargaining Agreement No. 25, enacted in 1975, primarily focuses on establishing the principle of equal pay and mandating gender-neutral job evaluation systems, rather than imposing explicit reporting or audit obligations on employers. Its core contribution lies in setting the legal standard for non-discriminatory remuneration and providing mechanisms for individual redress. The agreement itself does not require companies to submit regular reports on pay structures or conduct formal pay audits. Instead, its emphasis is on the inherent fairness of job classification and remuneration systems, with the expectation that adherence to gender-neutral evaluation criteria would prevent pay disparities from arising in the first place.

The concept of systematic pay gap reporting and audits for employers in Belgium was introduced much later, primarily through the Act of 22 April 2012 on reducing the gender pay gap. This subsequent legislation mandates that companies with 50 or more employees must prepare a detailed gender pay gap report every two years. These reports, which outline differences in pay and labor costs between men and women, are transmitted to the National Bank for public availability. Furthermore, companies with over 50 employees are required to establish a comparative analysis of their wage structure by gender every two years. If this analysis reveals a gender pay gap, the company must develop an action plan to address it.

While CBA No. 25 did not directly impose these reporting duties, its foundational requirement for gender-neutral job evaluation systems is intrinsically linked to the effectiveness of later pay gap reporting and auditing. The 2012 law, for instance, explicitly incorporates the obligation to check the gender-neutrality of collective bargaining agreements and function classification systems, a direct evolution from the principles established in CBA No. 25 and its amendments (25bis and 25ter). Therefore, while CBA No. 25 itself does not detail reporting frequencies or audit methodologies, it created the essential legal and conceptual framework that made such subsequent, more detailed, transparency and accountability measures possible and meaningful. The enforcement of CBA No. 25's principles through social inspection and the specialized commission also serves as a form of ongoing monitoring, albeit not a formal reporting obligation in the modern sense.

Governance & Enforcement Bodies

The enforcement and governance of Collective Bargaining Agreement No. 25 involve several key bodies within the Belgian labor law framework. The National Labour Council (Conseil National du Travail - CNT) is the primary body responsible for concluding interprofessional collective bargaining agreements like CBA No. 25. As a bipartite advisory body, the CNT brings together representatives of employer organizations and trade unions, facilitating social dialogue and the negotiation of national labor standards. Once an agreement is reached and rendered obligatory by Royal Decree, the CNT plays a role in its ongoing interpretation and potential revision, as seen with the amendments to CBA No. 25.

For the practical enforcement of the agreement at the enterprise level, the Social Inspection (Inspection sociale) services of the Federal Public Service Employment, Labour and Social Dialogue (SPF Emploi, Travail et Concertation sociale) are responsible. These inspectors monitor compliance with labor laws, including collective bargaining agreements, and can investigate complaints related to pay discrimination. Additionally, the Institute for the Equality of Women and Men (Institut pour l'égalité des femmes et des hommes - IEFH), established by a law of 16 December 2002, plays a crucial role in promoting gender equality and combating discrimination. While the IEFH was created much later than CBA No. 25, it now serves as a key actor in ensuring the respect of gender equality principles, including those related to equal pay, and can provide guidance and support in cases of discrimination.

Furthermore, CBA No. 25 itself established a specialized joint commission within the National Labour Council. This commission's mission, reinforced by CCT No. 25bis and 25ter, is to provide technical assistance to social partners in developing and analyzing gender-neutral job evaluation systems. This body acts as a resource for ensuring that the fundamental tools for determining pay are free from gender bias. In cases of alleged discrimination, employees can also pursue claims through the competent courts, which have the authority to enforce the provisions of CBA No. 25 and award remedies. The interplay between these bodies – the CNT for legislative creation and amendment, social inspection for general oversight, the IEFH for advocacy and guidance, the specialized commission for technical expertise, and the judiciary for dispute resolution – forms a comprehensive governance and enforcement framework for pay equity in Belgium.

Monitoring & Evaluation

The monitoring and evaluation of compliance with Collective Bargaining Agreement No. 25 primarily rely on a multi-faceted approach involving social inspection, the specialized joint commission, and the broader framework of Belgian labor law. The Social Inspection services are tasked with conducting inspections within companies to ensure adherence to labor legislation, including the provisions of CBA No. 25. These inspections can be proactive or triggered by complaints from employees or trade unions. When a complaint of pay discrimination is lodged, the Social Inspection investigates the matter, examining remuneration structures and job classifications to determine if the principle of equal pay for equal work or work of equal value is being upheld. This investigative power is a key mechanism for monitoring compliance at the enterprise level.

A significant aspect of monitoring specific to CBA No. 25 is the role of the specialized joint commission established within the National Labour Council. This commission, whose mission was reactivated and expanded by CCT No. 25bis (2001) and made compulsory by CCT No. 25ter (2008), is responsible for informing and sensitizing social partners about gender-neutral job evaluation systems. Its mandate includes gathering information on initiatives related to gender-neutral job evaluation and providing technical assistance. This ongoing role in promoting and reviewing the neutrality of job classification systems serves as a crucial, albeit indirect, form of monitoring the structural underpinnings of pay equity. The compulsory analysis of job classifications for gender-neutrality by all joint committees, as mandated by CCT No. 25ter, represents a systemic evaluation mechanism at the sectoral level.

While CBA No. 25 itself does not prescribe specific audit frequencies or detailed evaluation criteria for companies, the broader Belgian legal framework has evolved to include such mechanisms. For instance, the Act of 22 April 2012 on reducing the gender pay gap introduced requirements for companies with 50 or more employees to conduct biennial comparative analyses of wage structures and, if necessary, develop action plans. These later laws build upon the principles of CBA No. 25, integrating more formal monitoring and evaluation tools. The effectiveness of CBA No. 25 is also continuously evaluated through jurisprudence, as courts interpret and apply its provisions in individual cases, thereby shaping its practical impact and ensuring its ongoing relevance in the fight against pay discrimination. The requirement for CBA No. 25 to be annexed to company work regulations also facilitates internal monitoring by making its provisions readily accessible to all stakeholders.

Enforcement & Penalties

Collective Bargaining Agreement No. 25 provides specific enforcement mechanisms and outlines penalties for non-compliance, particularly concerning retaliatory actions against employees asserting their equal pay rights. If an employer dismisses a worker or unilaterally modifies their working conditions for reasons related to an equal pay complaint or legal action, such actions are deemed unjustified. In such instances, the employee or their affiliated trade union has the right to request reintegration into the company or reinstatement to their original position. This emphasis on restoring the employee's prior status underscores the protective nature of the CBA, aiming to prevent any adverse impact on workers who challenge discriminatory pay practices.

Should the employer refuse to reintegrate the employee or reinstate them to their position, the CBA stipulates a clear financial penalty. The employer must pay the worker an indemnity. This indemnity, at the choice of the employee, can be either a fixed amount equivalent to six months' gross remuneration or an amount corresponding to the actual damage suffered, provided the employee can demonstrate the extent of that damage. This provision for substantial compensation serves as a significant deterrent against employer non-compliance and provides a tangible remedy for victims of retaliation. The choice offered to the employee allows for flexibility, enabling them to seek a readily calculable lump sum or to pursue a claim for more extensive, proven damages.

Beyond these specific remedies for retaliation, the general principle of equal pay established by CBA No. 25 is enforceable through civil courts. Discriminatory provisions in employment contracts or internal regulations that contravene the principle of equal pay are considered null and void. While CBA No. 25 primarily focuses on civil sanctions, later Belgian anti-discrimination laws, such as the Law of 10 May 2007, and the Act of 22 April 2012 on reducing the gender pay gap, introduced administrative and criminal penalties for certain violations, including failure to comply with reporting obligations. For example, failure to publish broken-down data in the social balance sheet or to submit the biennial analysis report can trigger level-two sanctions, involving criminal fines ranging from €400 to €4,000 or administrative fines from €200 to €2,000. This layered approach to enforcement, with CBA No. 25 providing foundational civil remedies and later laws adding administrative and criminal sanctions, ensures a robust framework for upholding pay equity in Belgium.

Relationship to Other Laws

Collective Bargaining Agreement No. 25 operates within a complex and evolving legal landscape in Belgium, interacting with and complementing numerous national and international instruments. It was concluded under the framework of the Law of 5 December 1968 on Collective Bargaining Agreements and Joint Committees, which provides the legal basis for the negotiation and binding force of such agreements. This law ensures that once rendered obligatory by Royal Decree, CBA No. 25 has a broad and enforceable application. Furthermore, CBA No. 25 explicitly references and builds upon the Law of 12 April 1965 concerning the protection of workers' remuneration, reinforcing the principle that remuneration must be protected from discriminatory practices.

Internationally, CBA No. 25 directly transposes and aligns with key principles from the International Labour Organization (ILO) Convention No. 100 concerning Equal Remuneration for Men and Women Workers for Work of Equal Value (1951). It also implements Article 119 (now Article 157) of the Treaty establishing the European Economic Community (now the Treaty on the Functioning of the European Union), which mandates equal pay for male and female workers for equal work or work of equal value. The agreement was specifically influenced by and designed to implement the Council Directive 75/117/EEC of 10 February 1975, which aimed to harmonize Member States' legislation on equal pay. These international and European instruments provide the overarching legal context and impetus for CBA No. 25, ensuring Belgium's compliance with broader human rights and economic integration objectives.

In the decades following its adoption, CBA No. 25 has been complemented and reinforced by several significant national laws. The Law of 10 May 2007 to combat discrimination between women and men is a comprehensive anti-discrimination law that covers employment relations and reinforces the principle of equal pay. Additionally, CBA No. 95 of 10 October 2008, concerning equality of treatment during all stages of the working relationship, further strengthens the framework for non-discrimination, including in remuneration. Most notably, the Act of 22 April 2012 on reducing the gender pay gap introduced specific reporting and audit obligations for companies, building directly on the principles of gender-neutral job evaluation established by CBA No. 25 and its amendments (25bis and 25ter). This 2012 law mandates biennial pay gap reports and action plans for larger companies, providing concrete mechanisms to monitor and address disparities. Looking ahead, Belgium is currently in the process of transposing the EU Pay Transparency Directive (2023), which will introduce further obligations such as salary range disclosure in job postings and enhanced employee information rights, further building upon the foundational principles laid by CBA No. 25.

International Context

Collective Bargaining Agreement No. 25 is deeply embedded within a robust international and European legal framework for equal pay. Its very inception in 1975 was a direct response to, and a national transposition of, international and European obligations. Foremost among these is the International Labour Organization (ILO) Convention No. 100, adopted in 1951, which calls for equal remuneration for men and women workers for work of equal value. Belgium, as a member state of the ILO, is bound by this fundamental principle. The CBA also directly implements Article 119 (now Article 157) of the Treaty establishing the European Economic Community (EEC), which enshrined the principle of equal pay for equal work or work of equal value as a cornerstone of European law. This article has been extensively interpreted by the European Court of Justice, leading to a broad understanding of "remuneration" and "work of equal value."

Furthermore, CBA No. 25 was specifically influenced by and designed to implement the Council Directive 75/117/EEC of 10 February 1975, which aimed to facilitate the practical application of the equal pay principle across Member States. This directive provided a more detailed framework for national legislation, which CBA No. 25 effectively adopted. Over time, the European Union has continued to strengthen its equal pay legislation, notably with Directive 2006/54/CE on the implementation of the principle of equal opportunities and equal treatment of men and women in matters of employment and occupation (recast), which consolidated earlier directives. Most recently, the EU Pay Transparency Directive (Directive (EU) 2023/970), approved in 2023, marks a significant advancement, introducing comprehensive pay transparency measures and stronger enforcement mechanisms. Belgium is currently in the process of transposing this directive into national law by June 2026, building upon its existing framework, including CBA No. 25 and the 2012 Gender Pay Gap Law.

Belgium's commitment to pay equity, as evidenced by CBA No. 25 and subsequent legislation, has contributed to its relatively low gender pay gap compared to the EU average. In 2022, Belgium's unadjusted gender pay gap was 5%, significantly lower than the EU average of 12.7%. This achievement is a testament to the long-standing legal framework, initiated by instruments like CBA No. 25, which has consistently pushed for gender-neutral remuneration structures and robust enforcement. The European Social Charter (revised) of 3 May 1996 also affirms the right of male and female workers to equal pay for work of equal value (Article 4.3), providing another international layer of protection that aligns with the principles of CBA No. 25. The continuous evolution of Belgian law in response to and in anticipation of international and European standards demonstrates a proactive approach to achieving and maintaining pay equity.

Implementation Timeline

Date	Milestone	Status
1975-10-15	Conclusion and entry into force of Collective Bargaining Agreement No. 25	In Force
1975-02-10	Council Directive 75/117/EEC on equal pay adopted (influencing CBA 25)	Transposed
2001-12-19	Conclusion of Collective Bargaining Agreement No. 25bis (amending CBA 25)	In Force (Amended)
2008-07-09	Conclusion of Collective Bargaining Agreement No. 25ter (amending CBA 25)	In Force (Amended)
2008-09-28	Royal Decree rendering CCT No. 25ter obligatory	In Force
2012-04-22	Act on reducing the gender pay gap adopted	In Force
2023-06-07	EU Pay Transparency Directive (2023/970) effective date	Awaiting Transposition
2024-09-12	French Community of Belgium transposes pay transparency elements of EU Directive	In Force (Partial Transposition)
2025-03-15	Belgium publishes draft legislation for EU Pay Transparency Directive transposition	Proposed
2025-06-30	Expected conclusion of parliamentary committee debates on draft law	Proposed
2025-12-01	Expected final approval of transposition law by Federal Parliament	Proposed
2026-06-07	Deadline for EU Member States to transpose the EU Pay Transparency Directive	Awaiting Entry

Compliance Checklist

Requirement	Action Required	Deadline
Adherence to Equal Pay Principle	Ensure male and female workers receive equal remuneration for the same work or work of equal value.	Ongoing
Gender-Neutral Job Evaluation	Implement and maintain job classification and evaluation systems that are free from gender bias in criteria, weighting, and conversion to wages.	Ongoing
Inclusion in Work Regulations	Annex the full text of Collective Bargaining Agreement No. 25 (and its amendments) to the company's work regulations.	Upon establishment/amendment
Protection Against Retaliation	Refrain from dismissing or unilaterally modifying working conditions of employees who file equal pay complaints or initiate legal action.	Ongoing
Remedy for Retaliation	In case of unjustified dismissal/modification, offer reintegration or pay compensation (6 months' gross salary or proven damages).	Upon refusal of reintegration
Cooperation with Social Inspection	Cooperate with Social Inspection during investigations into alleged pay discrimination.	Upon request
Analysis of Job Classifications (Joint Committees)	Joint committees must analyze job classifications for gender neutrality (as per CCT 25ter).	Ongoing (Compulsory)
Biennial Gender Pay Gap Report (50+ employees)	Prepare a detailed report analyzing remuneration structures by gender.	Every two years (by 31 March of year following two financial years covered)
Action Plan for Pay Gaps (50+ employees)	If analysis reveals a gender pay gap, develop and implement an action plan.	As needed, following report
Social Balance Sheet (All companies)	Annually file a social balance sheet outlining pay and labor cost differences by gender with the National Bank.	Annually
Gender-Neutral CBAs (Industry Level)	Ensure industry-level CBAs and function classification systems are gender-neutral (checked by Employment Ministry).	Ongoing
Preparation for EU Pay Transparency Directive	Review and adjust recruitment practices (salary range disclosure, ban on salary history questions) and internal pay structures.	By June 7, 2026

Sources and References

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