As noted in the table above, the Ontario, and California Governments have each mandated annual reports on pay gaps inclusive of ethnicity to be published by workplaces. Both require that employers with 100 or more employees compile an annual report that contains an ethnic breakdown of their workforce and information on their wages.288 In Ontario, a designated government authority has the power to prosecute employers and appoint an officer to conduct an audit upon failure to provide a report.289 In California, a designated government authority can investigate and prosecute employers whose reports demonstrate (or have otherwise been reported) they are engaging in unlawful wage practices.290 The similarities within the legislation mean it would be possible to compare the success of these approaches in different situations. Scotland has taken a slightly different approach under the direction of the UK-wide Public Sector Equality Duty. Public sector authorities are subject to different reporting schedules, but reporting on ethnicity is being phased in from 2021–24. Broadly, it requires public authorities of 20 or more employees to publish a report every four years that includes employee information on wages, occupational segregation, workplace policy towards addressing inequities and progress made.291 Notably, mandatory reporting has been widely supported in the UK by unions and business lobby groups.292 Therefore, research from other countries indicates that there is a need to further investigate this approach and also have the New Zealand public sector lead the way in addressing the Pacific Pay Gap through public accountability measures. These actions could provide important intermediary steps between current practices and mandatory reporting. As noted above, it is far more common for other countries to require annual reporting on gender pay gaps without regard to intersecting ethnic pay gaps. Australian gender pay equity legislation is the most similar to the mandatory reporting on ethnic pay gaps in Ontario and California. In Australian gender pay equity legislation, private employers with 100 or more employees must submit an annual report to a specifically created stand-alone government agency, which must include: a breakdown of their workforce by gender, position level and remuneration; reporting on practices relevant to flexible employment; any instances of harassment or discrimination; and any consultation with employees on gender equality in the workplace. These reports are analysed by the authority body and returned to employers with feedback and suggestions. Organisations that fail to comply may be named and barred from tendering for government contracts.293 By comparison, gender pay equity laws in Europe take a different approach. In the UK, any organisation with 250 or more employees must submit gender and pay rates of their employees, alongside an optional narrative to complement the data. The regulations are enforced by the Equalities and Human Rights Commission, a non-governmental body that can require the submission of an action plan if a report is not issued.294 The Welsh and Scottish Governments have individually expanded upon this base requirement, and as explored above, Scotland’s commitments extend to ethnicity.295 In Denmark, private organisations of 35 or more employees with 10 or more men and women in the same job category or public organisations of 35 or more employees with three or more men and women in the same job category must annually report 288 Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America). 289 Pay Transparency Act, 2018, chap. 5, (Ontario, Canada). 290 Senate Bill No. 973, 2020, chap. 363 (California, United States of America). 291 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 14, 42; Equality and Human Rights Commission. Listed Authorities Covered by the Scotland Specific Duties. Scotland: Equality and Human Rights Commission, 2021. https://www.equalityhumanrights.com/en/public-sector-equality-duty-scotland/listed-authorities-covered-scotlandspecific-duties. 292 Makortoff, Kalyeena. “Businesses, Unions, and EHRC Press Government on Ethnic Pay Gap Reporting.” The Guardian, June 25, 2021. https://www.theguardian.com/business/2021/jun/25/cbi-tuc-and-ehrc-press-government-on-mandatory-ethnicpay-gap-reporting. 293 Ministry for Women, Country Case Studies, 1-2; Fair Work Ombudsman. Gender Pay Equity Best Practice Guide. Sydney: Fair Work Ombudsman, 2020. https://www.fairwork.gov.au/tools-and-resources/best-practice-guides/gender-pay-equity. 294 Ministry for Women, Country Case Studies, 20-21; Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 17; Equality and Human Rights Commission, Fair Opportunities for All, 25. 295 Brown, Rickard, and Broughton, Tackling Gender, Disability and Ethnicity Pay Gaps, 42-43; Equality and Human Rights Commission, Fair Opportunities for All, 25. Pacific Pay Gap Inquiry Literature Review 41