is one of the most straightforward means of solving such an issue.279 Most pay transparency policies do not specify ethnicity. Instead, they are often subsumed under gender pay equity legislation. However, existing pay transparency laws assume similar forms to mandatory reporting across a number of governments in North America. The most common requirement is the ban on pay secrecy, active in the US states of California, Colorado, Illinois, Louisiana, Maine, Michigan, Minnesota, New Hampshire, New Jersey and Vermont.280 Some governments prohibit employers from requesting wage or salary histories such as that in Ontario, Canada, and the US states of California, Delaware, Massachusetts and Oregon and the US cities of Philadelphia, Pittsburgh, New Orleans and New York.281 However, both Ontario and Colorado have developed more-comprehensive legislation that requires disclosure of expected remuneration in job advertisements.282 Germany’s Remuneration Transparency Act 2018 is often cited as an example of legislation that comprehensively addresses pay transparency.283 This legislation allows workers to request from their employer (a private employer with 200 or more employees), subject to several criteria, information regarding the remuneration of the other gender284 for the same or comparable work alongside the framework used to determine such remuneration.285 However, as with the pay transparency legislation explored above, although this approach is more detailed, it only addresses one tenet of pay transparency. Despite research indicating the pay transparency is a key mechanism for closing ethnic pay gaps, there is yet to be ethnic-specific legislation, and most pay transparency legislation has developed with a focus on gender pay gaps instead. 6.1.2 Mandatory annual reporting Annual reports published by workplaces that map their ethnicity pay gap are crucial for gathering extensive and rich data, which in turn holds workplaces accountable for remedying inequities.286 There are several examples overseas where reporting on gender pay gaps has been legally mandated, but few examples for ethnic pay gap reporting. Where mandatory reporting has been implemented, there is significant cross-over between states.287 279 Equality and Human Rights Commission, Fair Opportunities for All, 21-23. 280 Coghlan, State Policy Strategies for Narrowing the Gender Wage Gap, 1. 281 Coghlan, State Policy Strategies for Narrowing the Gender Wage Gap, 1. 282 Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America). 283 Ministry for Women. Country Case Studies on Pay Transparency. Wellington: Ministry for Women, 2019, 12. https://women. govt.nz/sites/public_files/Case%20studies%20on%20pay%20transparency%20-%20AU%2C%20DK%2C%20FR%2C%20 DE%2C%20IS%2C%20UK.pdf. 284 Language used reflects the source material. 285 Ministry for Women, Country Case Studies on Pay Transparency, 12-13. 286 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 42-43; Equality and Human Rights Commission, Fair Opportunities for All, 25-26; PricewaterhouseCoopers, Ethnicity Pay Gap Reporting, 2. 287 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 42; Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America). Pacific Pay Gap Inquiry Literature Review 39