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7. Projects, commissions, research and evaluations since 2019

This chapter summarises how issues related to work of equal value have been addressed in research, studies or government reports since 2019. This includes issues such as relationships in pay between work dominated by women and work not dominated by women, different ways of analysing pay statistics, the application of pay survey provisions, the role of collective agreements in promoting equal pay or governments’ strategic positions in this area. The compilation does not claim to be complete. The chapter is structured in such a way that it first provides an overview for each country. It concludes by commenting on possible commonalities or dividing lines.

Denmark

A pay structure committee, consisting of experts and representatives of social partners, carried out work over a period of two years that culminated in the Lønstrukturkomitéens hovedrapport (Pay Structure Committee’s Main Report) in 2023.
Andersen et al. (2023).
 One of the aims of the report was to develop a common frame of reference on issues related to pay structures and pay development, particularly in the public sector. Furthermore, the consequences of changing existing pay structures were to be highlighted, as well as opportunities for developing approaches to pay setting within the framework of the collective agreement model in the Danish public sector.
The report found that public sector occupations dominated by women are low-paid compared to other occupations with similar levels of education. The three public sector occupations that had most clearly climbed the pay hierarchy between 1969 and 2019 were police officers, train drivers and nurses. The pay structures are seen as a result of compromises and priorities governing the behaviour of parties in collective bargaining. The bargaining model is therefore considered to be unaffected by political influence or control. Within the framework of the committee’s work, no assessments were made of whether certain categories of workers could be described as undervalued or underpaid, compared with other categories of workers within the Danish labour market.
One of the committee’s tasks was to investigate whether there had been problems in relation to the requirement of equal pay for equal work and work of equal value under Ligelønsloven (the Equal Pay Act). The report concluded that there were no significant problems with compliance with the Equal Pay Act in the public sector. This conclusion was based on the fact that legal challenges to pay discrimination are extremely rare.
The committee’s work resulted in four recommendations for future and sustainable pay setting in the public sector:
  1. Transparency: Well-functioning and manageable pay setting should be supported by transparency and understanding of parties’ trade-offs and priorities, including with regard to the vertical and horizontal aspects of pay structures.
  2. Adaptability: Pay setting should support the attractiveness of the public sector and facilitate recruitment and retention of the necessary labour force.
  3. Proportionality and legitimacy: Pay structures should support pay commensurate with employees’ qualifications, experience, performance and tasks, and account for private sector pay relationships.
  4. Supporting the public sector’s mission: Pay structures should support the fulfilment of the tasks of public institutions and the public sector as a whole and the effective administration of collective agreements.
The Pay Structure Committee also commissioned VIVE to conduct a knowledge review of the explanations for and consequences of the gender-segregated labour market.
VIVE is a centre for social science research, https://www.vive.dk/en/vive-frontpage/.
 The report Forklaringer på og konsekvenser af det kønsopdelte arbejdsmarked (Explanations and consequences of the gender-segregated labour market) from 2022 provides an overview of studies published after 2015.
Holt, Helle and Søndenbroe, Katja Isa (2022).
 The theme of these studies is not limited to the situation in Denmark.
Researchers Jørgensen, Hansen and Taxhjelm from the Danish Institute for Human Rights published the report Kvindefag i historisk skruetvinge (Women’s trades in a historical clamp) in 2020 and the article ‘Half a century of female wage disadvantage’ in 2022.
Sørensen et al. (2020) and Sørensen, Skriver Jørgensen and Meiland Hansen (2021).
 These texts touch on the same theme that formed the basis for the work of the Pay Structure Committee. They examine the relative positions of 13 occupational groups in the public sector. The comparison is based on pay data from 1969 and 2019. The year 1969 is of particular interest, as the Danish Parliament, in the context of a civil service reform, defined and laid the foundation for the pay structure that 50 years later, with a few exceptions, still characterises the public sector. The study concludes that, within the framework of the collective bargaining model, parties have, to a large extent, replicated the values on which the 1969 civil service reform was based. The study concludes with a recommendation that a long-term plan is needed to close pay differentials between occupations dominated by women and those dominated by men and to break the gender divide in the labour market
The starting point of the 2020 study Den ’uforklarede’ del af forskellen mellem kvinders og mænds timeløn (The ‘unexplained’ part of the differential between women’s and men’s hourly pay) is that women have lower lifetime earnings than men.
Larsen, Verne and Højgaard Mikkelsen (2020).
 This is partly because they have lower hourly earnings on average. Previous studies have shown that half of this pay differential is related to different measurable characteristics, mainly that women and men operate in different areas of the labour market. The aim of this study is to provide more insight into the remaining half of the pay differential, i.e. the statistically unexplained part. The report concludes with a recommendation to use other, or rather complementary, control variables to analyse the gender pay gap in the labour market.
A study published in 2019, Do Firms Respond to Gender Pay Gap Transparency?, specifically investigated whether § 5a of the Equal Pay Act has led to measurable improvements with regard to the purpose of the provisions.
Bennedsen et al. (2019).
 The study is based on pay data for the period 2003–2008 and compares pay developments in firms with 35–50 employees with pay developments in firms with 25–34 employees. The study is summarised as follows:
For the first time we are able to document, that pay-transparency really works. A 7% reduction in the pay-gap may not sound impressive, but given the fact that only a limited number of firms in Denmark are governed by this legislation the effect is significant. We can even prove the effect amongst firms, that were not required to provide gender segregated pay-statistics. We know now that wage-transparency works and it is a measure that can be applied nationally as well as internationally.

Finland

In Finland, equal pay programmes have been in place since 2006, based on cooperation between the Government and social partners. The latest in the series is the Likalönsprogrammet 2020–2023 (Equal Pay Programme 2020–2023), which sets out a number of concrete measures to reduce gender pay differentials.
Government.fi (2021:1).
 The programme notes that the design of collective agreements is important in this context, as is the work on gender equality plans and pay surveys in individual businesses. Attention is also drawn to the issue of facilitating the interaction between paid work and parenthood. The programme states that the Government has initiated a number of research projects linked to the theme of work of equal value and the gender-segregated labour market. 
Ökad lönetransparens genom ändring av jämställdhetslagen (Greater pay transparency through changes in the Equality Act) is the final report produced by a working group appointed by the Ministry of Social Affairs and Health, which operated from 21/08/2020 to 31/08/2021.
Government.fi (2021:2).
 The task was to consider amendments to the Equality Act based on the pay transparency objective of the Equal Pay Programme. The working group’s report proposes strengthening the rights of staff, staff representatives and employees who suspect the existence of pay discrimination. It is also proposed that the enforcement of the prohibition on pay discrimination be made more effective and that employees who suspect pay discrimination on the basis of gender be given the right to obtain pay information on other employees from the employer. The rights of staff representatives to receive information during pay surveys, and the possibilities for employees to receive information about workplace gender equality plans and pay systems, should be strengthened. The report did not result in any concrete proposals for legislative amendments, as the employer representatives opposed any legislative changes and workers representatives demanded more extensive changes than those proposed by the Ministry.
The report Projekt likvärdigt arbete, slutrapport (Project Work of Equal Value, final report) from 2022 describes a research and development project that examined pay systems and assessed work requirement levels and how the principle of equal pay for work of equal value has been addressed in collective agreements and in some individual organisations.
Jämsén, Hietala and Maaniemi (2022).
 The final report makes the following recommendations, among others:
The review of work of equal value at workplaces can be promoted through locally agreed pay systems that apply to the whole organisation. Such a model needs to be supported in agreements concluded at the central level. Workplaces need to prioritise work on equality plans and pay surveys. Employees should also be provided with more information on pay systems and the bases for setting pay. The current legislation could be clarified, for example with regard to the definition of work of equal value and the role of collective agreements in this context. Cooperation between labour market organisations is seen as a precondition for improving gender pay equality.
The report Kollektivavtalens effekter utifrån ett könsperspektiv (The impact of collective agreements from a gender perspective) was published in 2023.
Nousiainen et al. (2023). The report is only available in a Finnish version.
 The report is based on previous findings that gender pay differentials can be linked to indirect rather than direct discrimination and to differentials in pay between work of equal value. The report takes a specialised look at one public sector agreement area (land surveying) and one private sector agreement area (the chemical industry). Among other things, it is noted that companies often follow several collective agreements or that the same collective agreement may have annexes relating to different groups of employees. Overall, it is common that the pay of all employees is not determined within the framework of a single pay system.
The report highlights a contradiction in labour market organisations’ declarations at a general level that they are committed to promoting gender equality and that they evaluate the gender impact of their own collective agreements. In practice, these declarations rarely seem to lead to specific actions that bring about change. When the organisations surveyed for the project were asked if they had taken any actions related to gender equality, the actions seem to relate to surveying the situation rather than making immediate changes in the content of collective agreements.
In their recommendations, the authors of the report refer to a large extent to the Pay Transparency Directive, which is expected to be adopted. This implies a need to better align the terminology of collective agreements with concepts arising from EU law. Another conclusion is that there is a need to coordinate the methods and tools used to evaluate work requirements. These valuations in turn influence pay structures and pay hierarchies. In this context, the authors refer to the section of the Directive that now constitutes Article 4.2. This provision underlines the responsibility of Member States to ensure that analytical tools and methods for assessing and comparing the value of jobs are made readily available. According to the authors, the development of analytical tools should be carried out in cooperation with social partners. Such a model could also be adapted to specific conditions within an individual sector. Other recommendations concern the need to specify pay criteria and their application, so that, for example, a collective agreement makes clear the relationship between the proportion of pay linked to work demands and the proportion of pay linked to an individual’s work performance. Furthermore, it is pointed out that under EU law an employer cannot rely on a discriminatory collective agreement to justify discriminatory practice. Instead, it would be reasonable for the penalties for discriminatory provisions to be borne primarily by the parties to the collective agreement when the individual employer has complied with the provisions of the agreement in good faith.
The report Statsrådets redogörelse om jämställdhetspolitiken (the Council of State’s Report on gender equality policy) from 2022 is structured around seven gender equality policy objectives.
Government.fi (2022).
 Goal 4 is entitled ‘Ett ekonomiskt jämställt Finland’ (An economically gender equal Finland), and the phrase ‘equal pay for work of equal value’ is central. It is worth noting that the report refers to a structural pay gap, which is established in the fact that work in sectors and occupations dominated by women is on average paid less than work in sectors and occupations dominated by men. The report points out that pay discrimination can occur when women and men do the same work but especially when the tasks are different but equally demanding.
This refers to a study from Larja (2019): Maahanmuuttajanaiset työmarkkinoilla ja työmarkkinoiden ulkopuolella. In the work: Kotoutumi­sen kokonaiskatsaus 2019: Tutkimusartikkeleita kotoutumisesta. Arbets- och näringsministeriets guider och övriga publikationer (Guides and other publications of the Ministry of Economic Affairs and Employment) 2019:10, pp. 28–42.
 According to the Council of State, achieving Goal 4 requires tackling pay discrimination, correcting pay structures that increase inequality and comparing pay across collective agreements. Furthermore, the requirements of work traditionally performed by women could be better taken into account than at present. Therefore, if necessary, the undervaluation of this work should be addressed. Structural change can be accelerated by promoting pay transparency. The report notes that the practice of tripartite cooperation, as advocated, among other things, by ILO Convention No. 100, has proved problematic in gender equality matters. It notes that the primary task of labour market organisations is to promote the interests of the groups they represent. Against this background, it will be difficult to gain acceptance for a permanent change in pay relations between different occupational groups. For this reason, the State needs to take greater responsibility for international human rights obligations.
Two research papers have addressed issues of pay setting from a gender perspective. Wage politics and feminist solidarity from 2021 describes a struggle among preschool teachers to raise their pay.
Koskinen Sandberg (2019).
 The background to these actions was a revelation in the Finnish media that several municipalities had secret agreements not to compete with each other in terms of pay despite a major shortage of preschool teachers. Implementing Equal Pay Policy, published in 2021, focuses on the nurses’ strikes for higher pay in 2007.
Saari, Kantola and Koskinen Sandberg (2021).

Iceland

The reports or studies referred to here largely pertain to experiences with the gender equality standard ÍST 85.
In 2021, building on Iceland’s commitments under ILO Convention No. 100 on equal remuneration for work of equal value, the Government established a working group based on tripartite cooperation. The work of the group is summarised in the document Recommendations on the Re-evaluation of Women’s Work (translated from Icelandic).
Government.is (2021).
 The document assumes that it is possible to assess and compare the demands of work for different occupations in the Icelandic labour market. Based on such an ambition, it might be possible to correct the pay gap between women and men. The following tasks were assigned to the working group:
  • Diagnose the problem. Establish a development project to assess the value of different occupations and thus identify the factors that typically lead to the undervaluation of women’s labour.
  • Develop tools. Together with the analysis, develop tools that capture and support the objectives of the Gender Equality Act and make it easier for employers to comply with the requirement of equal pay for work of equal value.
  • Together with social partners, develop negotiation procedures when issues of equal pay are raised. Examine the extent to which different employment relationships and outsourcing have an impact from a gender equality perspective.
  • Increase knowledge and awareness of the Gender Equality Act’s principle of equal pay for equal work, including through training, advice, and increased dialogue.
In 2024, the above working group produced the report Job Evaluation.
Government.is (2024).
 The report shows that the project’s ambitions could only be realised to a limited extent. The working group did not agree on all the conclusions of the report. This is reflected in a separate statement from the Confederation of Icelandic Enterprise (SA). It is noteworthy that joint work on developing a ‘toolkit’ and related educational material for job evaluation will continue and that the State is seen as a key player in this work.
The article ‘Equal Pay for Work of Equal Value? Iceland and the Equal Pay Standard’ was published in the journal Social Politics in 2022.
Wagner (2022).
 The study is based on in-depth interviews with key actors in the government office, employer organisations, trade unions, HR managers and people with specific expertise in international HR standards. The article provides an initial insight into the development process of the Icelandic standard. The study shows that there has consistently been a field of tension between different actors’ expectations of the standard. From the employer perspective, the standard is typically seen as primarily a technical aid to improve the pay-setting process itself. Other actors in research and some trade unions see a need to revise prevailing values of work dominated by women and those dominated by men. The interviews show that societal values coloured by gender stereotypes seem to indirectly influence job evaluations carried out in individual workplaces.
One issue that has not received much attention in the implementation of the equal pay standard is how work on pay surveys and certification interacts with the traditional bargaining system on pay setting. Experience so far shows that work on the standard within organisations is primarily based on dialogue between the employer and the certification body. This means that in many cases, the interaction with trade union representatives is fairly limited.
An article titled ‘Tailoring the tool to the reality or the reality to the tool? On the equal pay standard and the abolition of gender-based pay’ (loosely translated from Icelandic) was published in the Icelandic Review of Politics and Administration No. 2022:2.
Haraldsdóttir, Rafnsdóttir and Jónsdóttir (2022).
 It examined whether the equal pay standard could be said to have contributed to closing the gender pay gap. The study was based on interviews with staff from four certification bodies involved in the implementation of the standard. It also analysed changes in the gender pay differentials based on official statistics on pay over the period 2012–2020, comparing pay developments for women and men in individual organisations before and after participation in the certification process. In the study was shown that the introduction of the standard cannot have had more than a marginal impact on the gender pay gap. The differential in pay progression between those organisations that had implemented certification and those that had not was only 1 per cent. The gender pay gap across the country had narrowed by almost 8 per cent over the period. Furthermore, the survey revealed serious gaps in support or guidance from the authorities.
The Icelandic Government also recognises the limitations of the standard to influence the pay gap at a national level:
It is first and foremost a management requirement standard; an administrative tool designed to establish and maintain gender equality in pay systems within a company or an institution. It is not promoted and designed to tackle wage differentials between companies and institutions and the implementation of the Equal Pay Standard does therefore not address [the] gender-segregated labour market.
A working paper from Statistics Iceland, Icelandic gender pay gap analysis 2008-2020, analyses a number of variables to provide a better understanding of the figures underlying the official gender pay gap.
Calian (2021).
 One interesting variable used in the Icelandic report is the gender composition of an occupation (dominated by men, balanced and dominated by women). When this variable is included in the model, it significantly favours the pay of both women and men in occupations that are gender balanced, although more so for women than men. However, the results of this variable are not statistically significant.

Norway

Lønnskartlegging: et verktøy for et mer likestilt arbeidsliv? (Pay surveys: a tool for a more equal labour market?) is a report published in 2024. It first describes the legal framework around pay surveys and the mandate of the supervisory authorities involved.
Brandal Mykelbust, Teigen and Tica (2024).
 Then is examined how pay surveys are handled in practice in different organisations and how the results of the surveys are perceived and explained. The data used consists of 75 annual reports from major employers. An account of the work on pay surveys is included in these reports and all annual reports are made available via a link in a separate annex. The interviews conducted show that reporting is perceived to be resource intensive, and in some cases it may require an initial cost to implement due to a lack of procedures. The interviews also show that the work on pay surveys has led to new ways of analysing pay differentials and that in a number of cases it has led to corrections that would otherwise not have occurred. Opinions are divided on the value of analysing pay differentials based on the concept of work of equal value. Critics point out that the cause of these pay differentials is largely beyond the control of individual employers. In a final chapter various digital options are discussed, both to facilitate the work of analysing pay and to compile experiences of conducting local pay surveys at a national level. References are also made to similar projects outside Norway.
Bufdir is the authority whose remit includes providing advice and developing tools and methods for pay surveys. One of the reports reproduced in Chapter 6 is based on a commission from Bufdir. The following clickable document, which provides a template for analysing gender pay differentials, comes from the agency’s website: Likestillingsredegjørelse. Eksempelvirksomhet (Gender equality statement. Example business).
Bufdir, ‘Likestillingsredegjørelse, lønnsforskjeller’ (Equality statement, pay differentials), extract from document, 28 February 2024.
 It should be noted that the template for analysing gender pay gaps contains separate items for basic pay, irregular supplements, bonuses, and overtime pay. It also requires gender-disaggregated data on employee numbers with regard to fixed-term contracts, parental leave, actual part-time work and involuntary part-time work. It is clear from the template that a good gender equality analysis should be based on a combination of data on pay and working conditions.
An article from 2021, ‘Lønnsforskjeller mellom kvinner og menn – hvilken rolle spiller bedriften?’ (Pay differentials between women and men – what role does the company play?) analyses gender pay gaps in the Norwegian private sector.
Misje Østbakken and Frisell (2021).
 The study pays particular attention to whether the size of the company, i.e. the number of employees, has an impact. The material analysed shows that the gender related pay differentials are greater in small companies than in medium-sized companies. The largest gender related pay differentials are found in the largest companies. The study also shows that the size of enterprises has an impact on pay levels in general. One of the conclusions of the study concerns the reasons for the statistically unexplained gender pay differential of 9–10 per cent identified across the total material examined. This unexplained pay differential cannot be related to the fact that women and men typically work in different types of companies with different pay levels. Instead, the material indicates that the cause of the pay differentials lies within individual companies.
The report Likelønn og det kjønnsdelte arbeidsmarkedet. Individuelle preferanser eller strukturelle begrensninger? (Equal pay and the gendered labour market. Individual preferences or structural constraints?) from 2020 consists of two parts.
Wagner et al. (2020).
 The first is devoted to detailed analyses of national statistics on the pay differentials between women and men. Among other things, it finds that the income gap between women and men, calculated on an annual basis, is between 20 and 30 per cent depending on level of education. The differential in hourly earnings is 10.8 per cent for the entire labour market and 16.5 per cent among those with a university degree. The differentials in the unexplained pay gap are much smaller, 7.7 per cent for the whole labour market and 7.5 per cent among university graduates. The main factors explaining the pay gap are related to women’s and men’s choices to work in different sectors, industries and occupations.
The second part of the report is devoted to analysing explanations and strategies concerning the gender pay gap in two government inquiries and in a number of governing documents from the Norwegian Trade Union Confederation (LO). The report finds that there is a consensus that the pay gap is linked to the gender-segregated labour market. It is also noted that the two reports, NOU 2008:6 and NOU 2013:13, draw different conclusions regarding the so-called frontline labour model.
Regeringen.no (2008) and Regeringen.no (2013).
 The 2008 report concludes that parties’ pay bargaining systems under the frontline labour model contribute to reproducing and maintaining pay relations between women and men. The latter report emphasises the positive impact of the model on the Norwegian economy. Within LO, the issue of equal pay between women and men has tended to be treated as a question of raising low-pay groups, which has not necessarily benefited occupations dominated by women in the public sector. The basic material for the 2020:4 report also resulted in an English publication in 2021, Egalitarian inequality: Gender equality and pattern bargaining.
Wagner and Teigen (2021).

Sweden

In the early 2000s, the Gender Equality Ombudsman carried out extensive reviews of employer pay surveys. When the authority was disbanded and its responsibilities integrated under the new Equality Ombudsman with supervision of seven grounds of discrimination, the nature of the monitoring of pay surveys changed. The report Tio år med Diskrimineringsombudsmannen. En rapport om nedmontering av diskrimineringsskyddet (Ten years of the Equality Ombudsman. A report on the dismantling of discrimination protection) from 2020 describes how supervision was reduced to an advisory function and provides examples of sanctions or follow-ups no longer being applied when employers submitted inadequate pay surveys.
Svenaeus (2020).
 The report also states that the Equality Ombudsman has not pursued a single case on work of equal value.
Inadequate compliance with pay survey provisions has been a long-standing issue and one of the reasons the Government initiated an inquiry in 2018 with the aim of making the Ombudsman’s supervision more effective. The inquiry resulted in two different reports, Effektivare tillsyn över diskrimineringslagen (More effective supervision of the Discrimination Act) and Ett utökat skydd mot diskriminering (Increased protection against discrimination).
Regeringen.se (2020) and Regeringen.se (2021:2). The studies also address issues other than the supervision of pay surveys.
 Both reports have been submitted for consultation, but so far the Government has chosen not to put forward the legislative amendments proposed by the inquiry.
The only exception is a proposal to extend protection against discrimination in public services.
A study published in 2022, Decoupling gender equality from gender pay audits in Swedish municipalities, describes how the work with pay surveys is carried out in five municipalities.
Salminen-Karlsson and Fogelberg Eriksson (2022).
 The researchers found that the municipalities’ work with pay surveys resembles a bureaucratic exercise, with no practical significance for closing the gender pay differentials. The analyses on which pay surveys are based are rendered inconsequential for pay policy. Municipalities do not consider themselves to have the financial resources to change existing pay structures.
The Swedish National Audit Office published report 2019:16 Diskrimineringslagens krav på lönekartläggning – ett trubbigt verktyg för att minska löneskillnader mellan könen (The Discrimination Act’s pay survey requirements – a blunt tool for reducing gender pay differentials) on the theme of pay surveys.
Swedish National Audit Office, report 2019:16.
 A key finding of the report was that the provisions had limited ability to influence the pay differentials between women and men in the labour market as a whole. The methodological approaches in the report, and thus the basis for the Swedish National Audit Office’s conclusions, came to be questioned in the memorandum En kommentar till Riksrevisionens rapport 2019:16 om lönekartläggningsbestämmelser (A commentary on the Swedish National Audit Office’s report 2019:16 on pay survey provisions).
Rickne and Stüber (2019).
 The Government responded to the National Audit Office’s report in skrivelse 2019/20:48 (Communication 2019/20:48).
Regeringen.se (2019).
 The Government concluded, among other things, that the legislative amendment that entered into force in 2017, as well as additional strengthening measures introduced at that time, must be given time to have an impact. The communication made a number of proposals on how to improve the interaction between the collective bargaining system and legislation. Some of these proposals, such as improved pay statistics at the employer level or other appropriate levels, were included in the mandate to the Commission on Equal Lifetime Earnings (Kommissionen för jämställda livsinkomster).
This Commission’s work is summarised in its final report Minska gapet. Åtgärder för jämställda livsinkomster (Reducing the Gap. Measures to equalise lifetime incomes) SOU 2022:4. The report provides a detailed description of the state of knowledge regarding job evaluations, pay surveys, pay statistics from a gender equality perspective and initiatives to increase pay transparency in the EU, Iceland and various Anglo-Saxon countries. A specific background report, Likalönelagar i Kanada (Equal pay laws in Canada), was instigated by the Commission.
Svenaeus, Lena (2021).
 One of the Commission’s suggestions is to clarify the conditions under which the market pay situation constitutes an acceptable reason for departing from the principle of equal pay. The Canadian report gives examples of how such legislation is organised in the provinces of Ontario and Quebec. Furthermore, the Commission calls for new regulation that combines effective enforcement and active dissemination of information to those affected, i.e. both local and central labour market parties. The Commission also favours a requirement for pay reporting, but states that reported pay data should be the result of a collaborative process at the local level. The Icelandic model is considered to have both advantages and disadvantages. One advantage compared with the system that applies in Sweden is that there are considerably more checks on pay surveys carried out by Icelandic employers. A disadvantage is the lack of a requirement to cooperate with local employee representatives. With regard to existing pay statistics, a review of existing occupational codes is recommended, as many occupations dominated by women have broader classifications than those dominated by men. The Commission also sees the need for a broader discussion on different methods of analysing and calculating horizontal and vertical pay segregation in the labour market, in order to better understand the extent of different forms of discrimination.
The Swedish Confederation of Trade Unions (LO) emphasises that the trade union movement plays an important role in putting pressure on politics. It is a matter of living up to the gender equality policy goal of women and men having the same opportunities and conditions in terms of power, influence and economic independence. The report LO:s jämställdhetsbarometer 2023 (LO’s Gender Equality Barometer 2023) emphasises LO’s goal of ending value discrimination against professions dominated by women.
Bergold, Lorentzi and Löfgren (2023).
 The way to achieve this is for social partners to take joint and long-term responsibility for equal pay throughout the labour market. Special efforts to raise the lowest pay in labour occupations must continue. In order to equalise the differentials, minimum pay must on average increase by a higher percentage than the average pay for workers.
In 2023, the Swedish Gender Equality Agency published the report Likvärdiga yrken – likvärdiga kollektivavtal (Professions of equal value – collective agreements of equal value).
Calleman (2023).
 The review of a number of employment conditions in collective agreements for organisations providing welfare services compared with equivalent conditions in a number of male-dominated industries shows that the differences are not particularly large and do not have a clear direction. To identify obstacles to equal treatment at a local level, it is proposed that the active measures in the Discrimination Act be expanded in scope or that meanings be specified. For example, it is only clear from the preparatory work, but not from the legal text, that active measures by employers should include the distribution of full-time and part-time employment and of fixed-term and permanent employment. It is also noted that a general strengthening of active measures could be achieved by introducing procedural rules on forms of cooperation between employers and employee representatives. Such rules could be included both in legislation and in collective agreements. Similar rules exist today in the Co-determination Act and the Work Environment Act. Another prerequisite for both current and future legislation on active measures to be effective is that the rules are enforced by means of supervision and sanctions. 
Every June, the National Mediation Office publishes a report analysing the development of the pay differentials between women and men over the previous year. The latest report, Löneskillnaden mellan kvinnor och män 2022 (Pay differentials between women and men 2022),
Medlingsinstitutet (Swedish National Mediation Office; 2023:1) Löneskillnaden mellan kvinnor och män 2022 (The gender pay gap in 2022).
 shows that between 2007 and 2019, the average pay differential fell from over 16 per cent to less than 10 per cent. Over the last three years, the pay differential has remained more or less stable. The standardised weighted differential, which takes into account, among other things, the fact that women and men work in different occupations and sectors, has even shown a slight increase. In June 2023, the National Mediation Office presented the results of a government commission with a broader remit, Inkomstskillnader mellan kvinnor och män (Income differentials between women and men).
Medlingsinstitutet (Swedish National Mediation Office; 2023:2) Inkomstskillnader mellan kvinnor och män (Income differentials between women and men).

Summary and a Nordic perspective

The studies and reports presented in this chapter make it clear that the principle of equal pay for work of equal value, which at its core is based on comparisons within an individual employer activity, is linked to structural and societal perspectives. When pay differentials is measured at the national level, the main contributory factor to the pay gap is differentials in pay levels between occupations and sectors dominated by women and those dominated by men. When applying a structural perspective, the responsibility for these differentials in pay also shifts from representatives of social partners to the state. The potential for policy to influence the rules of the game for social partners is seen in a number of ways: through decisions to expand or reduce specific parts of the public sector, through the design of conditions for childcare, elderly care, parental leave and care of close relatives or by contributing to frameworks that promote a ‘frontline labour model’ that has potential to change pay relations between different sectors.
The Nordic Council of Ministers’ report Gender-equal pensions in the Nordics illustrates how differentials in pay between women and men can be balanced through different strategies to promote equal pension levels.
Andersson (2023).
 The table below comes from this report:
Total gender pension gap 65+ year 2019
Nordic Council of Ministers (2019, p. 13).
Denmark
Finland
Iceland
Norway
Sweden
Total gap 65+
8%
24%
5%
23%
28%
Public pension
-5%
23%
-21%
22%
18%
Occupational pension
23%*
**
20%
19%*
48%
Private pension
-
34%
54%
-
25%
The figures show the pension gap of each type of pension for average female and male pensioners in each country. In Denmark and Norway public pensions distribute more income to women than to men, therefor the negative figures.
* Includes occupational and private pensions.
** Occupational pension is very rare in Finland and cannot be separated from the rest of the data. It could be included in both public and private pensions.
ILO Convention No. 100 is ultimately about state responsibility. At the same time, this chapter recognises that the issue of work of equal value lies in a field of tension between different arenas and actors, such as:
  • Representatives of employers and employees in individual organisations with the ability to conclude collective agreements at the local level. Local representatives may also have obligations to cooperate on pay surveys based on equal work and work of equal value.
  • Employer and trade union organisations at the union or central level with the ability to conclude collective agreements.
  • Reporting, analysing and publishing pay statistics related to the national level, preferably within the framework of Agenda 2030.
  • National human rights body that supervises discrimination legislation and can represent individuals in discrimination disputes.
  • The ability of politicians to steer the agenda by setting up inquiries or commissions and to change framework conditions by means of statutes, defining budgetary frameworks at the national or regional and municipal levels, etc.
There are striking differences between countries in the way the theme of work of equal value is treated. The Danish reports tend to focus on the issue of structural pay differentials at a general level, without explicitly addressing the issue of work of equal value. The fact that judicial reviews of equal pay issues are rare led the Pay Structure Committee to conclude that there are no significant problems regarding compliance with equal pay legislation. The conclusions of the Finnish Statsrådets bedömning om jämställdhetspolitiken (the Council of State’s assessment of gender equality policy) differ.
The Council of State is a central part of Finland’s political system and the body with the highest executive power in Finland. The Council of State is responsible for day-to-day administration and decision-making in Finland.
 The report states that pay discrimination can occur when women and men do the same work, especially when their tasks are different but equally demanding. The Council of State considers it necessary to intervene in pay discrimination and to correct pay structures that increase gender inequality. Furthermore, there should be a reassessment of the demands of work in different sectors and a comparison of pay across collective agreements.
At the centre of Iceland’s reporting are various assessments of the application and impact of the ÍST-85 standard. Amendments to the Gender Equality Act, which came into force in 2018, made the standard mandatory for employers with at least 25 employees. Trade union organisations have argued that too little attention has been paid to pay analyses and corrections due to ÍST-85 and to the interaction with the traditional bargaining system for pay setting. The standard favours interaction between employers and certification bodies, to some extent at the expense of traditional forms of interaction with trade union representatives. The study Skräddarsy verktyget efter verkligheten eller verkligheten efter verktyget (Tailoring the tool to the reality or the reality to the tool) has attracted some attention as it shows that the introduction of the standard has not had more than a marginal impact on the development of the gender pay gap. In Iceland too, there is a call for better support measures from authorities to carry out analyses at the operational level.
Reporting from Norway characterises developments as being in their start-up phase, with requirements for pay surveys introduced in 2018. The agency Bufdir is a driving force in initiating both research on gender pay differentials and developing templates and tools for social partners’ work on pay surveys. The report Likelønn og det kjønnsdelte arbeidsmarkedet. Individuelle preferanser eller strukturelle begrensninger (Equal Pay and the Gendered Labour Market. Individual preferences or structural constraints) notes that two government inquiries have come to opposing views on the frontline labour model and the extent to which it contributes to reproducing and maintaining pay relations between women and men. Issues surrounding the frontline labour model from a Nordic perspective are discussed in more detail in Chapter 10.
The content of documents from Sweden are distinctive in two ways. Firstly, the link between equal pay and equal income is a theme in three of the Swedish reports: the Swedish Gender Equality Agency’s report 2022:2 Ekonomisk jämställdhet (Economic equality), the report SOU 2022:4 from the Commission for Equal Lifetime Earnings, and the National Mediation Office’s report Inkomstskillnader mellan kvinnor och män (Income differentials between women and men). Secondly, a number of problems with applying the pay survey provisions are highlighted, largely related to a lack of supervision and shortcomings in advice and support for representatives of social partners. There is also a perceived difficulty in assessing which work is of equal value and a lack of guidance on this issue in collective agreements.
There are examples of conflicting conclusions on whether pay transparency and gender pay statistics can be said to have an impact on the pay gap between women and men at the national level. A Danish study from 2019 identified a 7 per cent reduction in the gap over a five-year period. The authors of an Icelandic study from 2022 came to the opposite conclusion. Using pay data from 2008 to 2020, they found that the introduction of the equal pay standard had only a marginal impact on the national gender pay gap
Country reports on the implementation of ILO Convention No. 100 and ILO comments on these reports reveal that there are tensions over the meaning of the term samma källa (single source).
 The issue relates to different conceptions of the external bounderies for comparing pay differentials between work of equal value. The final report of the Finnish Project work of equal value makes an interesting observation on the extent to which centralised or decentralised pay formation affects progress towards equal pay at the operational level. The report concludes that analyses of work of equal value in the workplace should be promoted by locally agreed pay systems that apply to entire organisations. In such a situation, there need never be any ambiguity about the ‘source’ of pay determination. Such a model, according to the authors, would in turn need to be supported through agreements concluded at central level.
Something that can be seen as common from a Nordic perspective, is that tripartite commissions dealing with the issue of equal pay have all established. In Denmark Lönestrukturkommittén (the Pay Structure Committee), in Finland Likalönsprogrammet (the Equal Pay Programme) and in Iceland the Task Force on Pay Equity and Equality in the Labour Market. With regard to the achievements of these commissions, either there was no mandate to specifically address gender imbalances in the labour market, as was the case in Denmark, or where such a mandate was more explicitly formulated, as in Finland and Iceland, the results in terms of concrete measures were extremely limited. In Finland, the work of the Commission did not result in any concrete proposals for legislative changes. The reason for this was that employer representatives were opposed to any legislative changes and employee representatives demanded more extensive changes than those proposed by the Commission. What the Icelandic parties were able to agree on was the State’s responsibility to develop pay analysis tools and provide necessary information to facilitate the application of the equal pay standard.
Nordic Council of Ministers I /www.norden.org/publications I pub@norden.org