The EUPTD mandates pay reporting for organisations with at least 100 employees, with a staggered implementation for smaller companies (150-249 by 2027, 100-149 by 2031). The Finnish proposal aligns with this. 

Finland proposes that employers will submit the necessary data to a single source: the incomes register, instead of reporting pay gap data to multiple entities. The data would flow from the incomes register to the Statistics Centre, which compiles the information and then forwards it to the Equality Ombudsman. While the data for the key metrics are stored in the incomes register, the calculations for these metrics are done by the Statistics Centre. However, the gender pay gap broken down by employee groups must be calculated by the employer and then reported to the incomes register. This is because the necessary data for this specific calculation is not available within the incomes register. This system allows the Equality Ombudsman to effectively monitor employer compliance with pay gap reporting requirements.

The EUPTD requires effective, proportionate, and dissuasive penalties, including fines. Finland proposes a specific "negligence fee" for non-compliance with joint pay assessment obligations. The neglect fee is at least EUR 5,000 and at most EUR 80,000. A conditional fine would be available if necessary to enforce compliance with the obligations proposed in the Equality Act, as required by the Pay Transparency Directive. For instance, if employers neglect their reporting obligation, the Incomes Register Unit could impose a conditional fine to enforce compliance with the reporting obligation.

The EUPTD requires a joint pay assessment if a 5% pay gap cannot be justified by objective criteria and is not remedied within six months. Finland maintains this trigger.

Finland emphasises the role of social partners in implementing the Directive, particularly in collective bargaining and developing tools for work evaluation. This aligns with the Finnish tradition of strong social dialogue.

Finland explicitly requires information provided to employees and job applicants to be accessible (including persons with disabilities), aligning with broader accessibility goals.

The Finnish proposal strongly focuses on pay transparency measures, such as providing starting salary or pay range information to job applicants and access to pay information for employees. This aligns with the Directive's aim of increasing pay transparency.