Portugal's Equal Pay Enforcement Under Law 60/2018 — ACT Notify-and-Correct System

Portugal's Law 60/2018 (in force since 2019) requires private and public employers with 50 or more staff to submit employee-level pay data by gender, job category, qualification and employment type as part of their mandatory annual 'Relatório Único'. The Authority for Working Conditions (ACT) analyses this data centrally; where it finds a pay gap of 5% or more between men and women in the same job category without an objective justification, it formally notifies the employer, which then has 120 business days to submit either a documented justification or a corrective evaluation plan, coordinated with the Commission for Equality in Labour and Employment (CITE). Employers who fail to submit a required plan risk administrative sanctions and exclusion from public procurement.
In early 2025, ACT notified approximately 1,540 employers with 50+ workers — about 20% of Portugal's roughly 7,700 covered companies — for unjustified pay disparities of 5% or more, giving the mechanism a concrete, publicly reported enforcement footprint rather than a purely declaratory reporting duty. Portugal's overall gender pay gap stood at 13.3% as of 2023 reporting, equivalent to women effectively working over 48 unpaid days a year relative to men; the law does not by itself claim to have closed this gap, and no independent study isolating its causal contribution to the national trend was found, but the notify-and-correct enforcement data is itself a directly measured outcome.
The model is now informing Portugal's transposition of the EU Pay Transparency Directive (2023/970/EU), due by June 2026, with CITE running a dedicated Equal Pay Transparency project since January 2025 to build a gender-sensitive job-evaluation tool and train labour inspectors and employers ahead of the wider EU regime.

Read the full analysis: https://trusaic.com/resources/global-pay-transparency-center/portugal/