gender pay statistics to Statistics Denmark. However, this law is unenforced.296 In France, employers with 50 or more employees must annually publish their own score relevant to gender pay gap indicators. The Labour Ministry enforces this, and non-compliance or a poor score is punishable by a fine.297 Similarly, Iceland requires employers with 25 or more employees to obtain annual certification of gender pay equity, which is granted after completing an audit by a designated government body. The authority body may issue fines for non-compliance, although, interestingly, unions and employer representatives are tasked with monitoring compliance.298 Increasingly in the UK, companies are opting to create internal policies that reflect annual reporting. Business in the Community, a businessled membership organisation, has an extensive list of signatories to their Race at Work Charter that commit to “capture ethnicity data and publicise progress” which has contributed to 19 percent of all companies in the UK publicly reporting pay gap data in 2021.299 Alongside the Charter, Business in the Community has developed clear fact sheets to support private companies in collecting and justifying the need to collect ethnic data.300 An example of a charter signatory is KPMG in the UK, which produces an annual report into pay gaps that is inclusive of ethnicity and sees it as a core part of its business: We do not want gender, ethnicity, identity, disability or background to be a barrier to anyone’s career at KPMG. That’s why we are voluntarily publishing our sexual orientation and disability pay gaps for the first time this year. We want to be as transparent as possible on the gaps that exist and how we are closing them.301 42 Business in the Community also produces an annual Race at Work scorecard that gives increasingly clear data not just on progress towards closing pay gaps but also experiences within the workplace, creating a form of accountability in the business community that is outside of legislation.302 Research of the above-mentioned jurisdictions has shown that, where pay gap reporting became mandatory, the pay gap reduced overall. Analysis applying the impact of pay gap reporting in other countries to the New Zealand context showed that a woman earning the current median wage in New Zealand ($26.37) could receive $12.80–$35.77 more per week. The report from the Mind The Gap campaign analyses public pay gap reporting impacts in seven countries and shows mandatory reporting can reduce gender pay gaps by 20–40 percent.303 6.1.3 Issues with pay transparency and mandatory reporting legislation A clear issue with current and proposed pay transparency and mandatory reporting is its significant focus on gender, with ethnicity or race being left as a voluntary measure. Other issues include inconsistencies regarding: which legislation applies to certain employers and what they mandate; the allocation of responsibility between employers, the government or an independent body; and the methods, or lack of, for enforcement and penalty. For instance, many pay transparency and mandatory reporting laws apply only to public employers and employees.304 296 Ministry for Women, Country Case Studies, 4-5. 297 Ministry for Women, Country Case Studies, 8-10. 298 Ministry for Women, Country Case Studies, 16-17. 299 Race at work charter: Business in the Community. Race at Work Charter. London: Business in the Community, 2021. https:// www.bitc.org.uk/post_tag/race-at-work-charter/; Business in the Community. Race. London, Business in the Community, 2021. https://www.bitc.org.uk/race/#h-about-the-race-at-work-charter. 300 Business in the Community. Capturing Ethnicity Data. London: Business in the Community, 2019. https://www.bitc.org.uk/ capturing-ethnicity-data/. 301 KPMG. UK Pay Gap Report 2020. London: KPMG, 2021, 2. https://assets.kpmg/content/dam/kpmg/uk/pdf/2021/02/KPMG-UKPay-Gap-Report-2020.pdf. 302 Business in the Community. Race at Work 2021: The Scorecard Report. London: Business in the Community, 2021, 13-19, 22. https://www.bitc.org.uk/report/race-at-work-2021-the-scorecard-report/. 303 Mind the Gap. The Potential Impact of Pay Gap Reporting on Wages in New Zealand. 2022. https://static1. squarespace.com/static/611321349d4ee10c3e086b1d/t/626dbd3e0d13d3686ede3ca8/1651359039546/ Research+note+impact+of+pay+gap+reporting.pdf. 304 Coghlan, State Policy Strategies for Narrowing the Gender Wage Gap, 5; Pay Transparency Act, 2018, chap. 5, (Ontario, Canada); Senate Bill No. 973, 2020, chap. 363 (California, United States of America).