1. Brazilian Context & Regulations

Purpose

Help Brazilian private-sector employers measure, report, and address their gender pay gap in line with national law and best practice.

Audience

• CEOs & Board members
• HR & Compensation teams
• Legal & Compliance officers
• Diversity & Inclusion leaders
• Payroll & Data analysts

Key Legal Requirements

• Law 14.611/2023 (Equal Pay Law): Private companies with ≥ 100 employees must submit pay data to the government in February and August, and publicly publish gender pay gap results in March and September each year.
• CLT (Labour Code): Prohibits discrimination in remuneration based on gender.
• Law Maria da Penha: Recognizes economic violence (unequal pay) as domestic violence.
• Ministry of Labour Guidance: Instrução Normativa MTE No. 41/2020 requires large companies to share salary data with unions.

Voluntary & ESG Frameworks

• Ethos Institute, IBRI guidelines
• UN Women’s Women’s Empowerment Principles (WEPs)
• Corporate Sustainability Reporting aligned to CSRD/ESRS

Why Conduct a GPG Analysis?

To identify pay disparities, comply with national law, strengthen employer brand, and meet stakeholder/ESG expectations.

2. Gap Calculation Methodology

1. Select Snapshot Date

Pick a consistent date each year (e.g., December 31). Use the same date for reporting and publication.

2. Data Collection

Extract the following from your HRIS/payroll:

3. Data Cleaning

• Convert all salaries to full-time equivalent (FTE).
• Ensure all figures are in BRL at snapshot exchange rate.
• Map any uncoded roles to the closest CBO category.

4. Calculate the Gender Pay Gap

Formula:
(Men’s average or median pay − Women’s average or median pay)
÷ Men’s average or median pay × 100

5. Test Common Drivers

• Unequal pay for equivalent roles
• Over-representation of men in leadership
• Segregation in high- vs. low-pay occupations
• Unequal part-time participation
• Differences in hiring, promotion, and turnover

3. CBO Occupational Classification

What Is the CBO?

The Brazilian Occupation Classification (CBO) is maintained by the Ministry of Labour and Social Security and underpins official employment surveys (RAIS, CAGED, PNAD).

Structure

• 1-digit: 10 Major Groups (e.g. 1 – Professionals; 2 – Technicians; 3 – Machine Operators).
• 2-digit: Sub-major groups (e.g. 11 – Health Professionals).
• 3 & 4-digit: Groups & subgroups of occupations.
• 5 & 6-digit: Unit codes (e.g. 223205 – “Human Resources Analyst”).

Assignment & Validation

• Map each internal job title to the nearest CBO code.
• Perform an internal audit (HR & IT) for consistency.
• Ensure each group has ≥ 5 employees before publishing.

Why Use CBO?

• Neutrality: based on tasks, education, and experience.
• Comparability: aligns with IBGE and MTP statistics.
• Granularity: from broad (1-digit) to detailed (6-digit).
• Transparency: publicly documented codes and definitions.

Next Steps

• Upload CBO mappings into your analytics system.
• Generate internal GPG reports by CBO + seniority.
• Share findings with leadership, unions, and employees.
• Develop action plans to close identified gaps.

How Brazil Uses the CBO to Classify Occupations

1. Underlying Taxonomy: CBO

The Brazilian Occupation Classification (CBO) is maintained by the Ministry of Labour and Social Security (MTPS) and used by IBGE, RAIS and CAGED surveys. It groups jobs by tasks, skills and educational requirements, ensuring a neutral, standardized foundation for pay-gap analysis.

• Major Groups (1-digit, 10 families): e.g. 1 – Legislators & Senior Officials; 2 – Professionals; 3 – Technicians; 4 – Clerks; 5 – Service Workers; 6 – Traders; 7 – Operators; 8 – Labourers; 9 – Armed Forces; 0 – Undefined.
• Sub-Major Groups (2-digit): splits each major group into 2–4 categories.
• Minor Groups (3-digit): more targeted job families.
• Unit Groups (4-digit): clusters of similar occupations.
• Occupation Units (5 & 6-digit): specific job titles (e.g. 311310 – “Human Resources Analyst”).

1.5. Connection to ISCO-08

To enable international comparability, each CBO code is mapped to its equivalent ISCO-08 category. The mapping logic is:

• MTPS maintains a crosswalk table aligning CBO 4-digit unit groups to ISCO-08 4-digit unit groups.
• Mapping is based on task and qualification descriptions in both taxonomies.
• Where no direct one-to-one exists, broader ISCO categories are used, with notes on partial matches.
• This allows Brazilian GPG reports to be benchmarked globally under an ISCO framework.

2. Law 14.611/2023 & Reporting Cadence

Under Brazil’s Equal Pay Law (14.611/2023), private companies with 100+ employees must:

• Submit pay data to the government every February and August.
• Publicly publish their gender pay gap results each March and September.

3. Assignment Sources & Logic

Employer mapping: HRIS export or manual mapping of each job title to its closest CBO code. Government validation: checks for valid codes, minimum group sizes (≥5 employees), and flags outliers. Currency & FTE: Salaries converted to full-time equivalent in BRL as of the snapshot date.

4. Why This Structure Works

• Objectivity: Published by MTPS, free from proprietary weighting.
• Comparability: Aligns with IBGE labour statistics and global ISCO-based benchmarks.
• Granularity: Drill down from 1-digit majors to 6-digit specifics or aggregate to ISCO levels.
• Neutrality: Based solely on job content—tasks, qualifications, experience.

5. In Practice

1. Choose your snapshot date (e.g. December 31).
2. Map each employee’s job title to a CBO code in your HRIS, capturing CBO + seniority level.
3. Ensure each CBO code is cross-referenced to the corresponding ISCO-08 code for global comparability.
4. Prepare your dataset (gender, CBO, ISCO, base & total remuneration, FTE, employment status).
5. Submit to government in February/August via the official portal.
6. Publish results in March/September on your website and communicate to stakeholders.