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Update: Pay Transparency Report

March 27th, 2024

On March 26, 2024, the decision given in the Public Civil Action filed by the Federation of Industries of the State of Minas Gerais (FIEMG) that suspended the obligation for companies with more than 100 employees to publish the Salary Transparency Report was withdrawn.

The subject is of great relevance, as companies will have until March 31 to publish on their websites and social networks the Salary Transparency and Remuneration Criteria Report, which was made available by the Ministry of Labor – Portal Emprega Brasil, on March 21, 2024.

Therefore, if a company does not intend to publish the report, the appropriate route will be to file an individual lawsuit. 

Failure to publish the report without support from a court decision will expose the company to fines in the amount equivalent to 3% of the payroll, limited to 100 minimum wages. The report could be used inappropriately in individual complaints to prove salary differences due to gender, discriminatory conduct, among other points.

If the company decides to continue with the publication, our recommendation is that it publish, together with the report in question, an explanatory note indicating the inconsistencies and the measures it adopts aimed at inclusion and promoting diversity.

Demarest’s Labor team is available to assist with any queries you may have in this regard.

Check out the Salary Transparency Report (Portuguese only)