Brazil’s pay transparency law is reshaping how companies approach compensation and compliance. If you have 100 or more employees in Brazil, you’re now required to report salary data, disclose pay gaps, and prove you’re paying employees fairly for equal work. For HR and payroll leaders, that means collecting, analysing, and publishing compensation information or facing substantial fines and reputational risk. This expert guide covers the essentials: who the law affects, what you need to report, how to prepare, and the tools to help you get it right from day one.
For a broader overview of hiring, payroll, and compliance in Brazil, see our Complete Guide to Doing Business in Brazil, it covers everything from tax rules to employee benefits.
At-a-Glance Summary of Brazil’s Pay Transparency Law
| Requirement | Details |
| Law | Law No. 14.611/2023 |
| Effective Date | July 2023 |
| Applies to | Employers with 100+ employees in Brazil |
| Threshold Includes | Full-time, part-time, and contractors under direct management |
| Data to Publish | Salary ranges, diversity stats, pay criteria |
| Update Frequency | At least annually (may be semi-annual) |
| Maximum Penalty | R$50M (LGPD breach) |
What Is Brazil’s Pay Transparency Law?
Brazil’s pay transparency law—Law No. 14.611/2023, in effect since July 2023 requires companies to disclose salary ranges, report on pay gaps, and publicly share the criteria used for compensation. The goal: to promote fair pay practices and eliminate unjustified gaps between employees in similar roles.
Why Brazil Introduced Pay Transparency Rules
The intent is clear: close unjustified pay gaps, especially between genders, and drive fair pay practices nationwide. According to IBGE, women in Brazil still earn over 20% less than men in equivalent roles. The law aligns with International Labor Organisation (ILO) standards and global ESG expectations, making pay equity part of a company’s compliance, sustainability, and reputation agenda.
This is not just a legal box to tick. Transparent pay practices can improve employee trust, reduce turnover, and enhance your standing with investors, regulators, and job candidates.
Who Must Comply with Brazil’s Pay Transparency Law
Private-sector employers in Brazil with 100 or more employees are required to comply with these regulations. Multinational companies with operations in Brazil are also covered—local or global, if you employ 100+ people in Brazil (including through subsidiaries, EORs, or branches), you must comply. The 100-employee threshold is based on total headcount (full-time, part-time, and contract staff under direct management), calculated across all local entities.
Reporting Requirements Under Brazil’s Pay Transparency Law
You’ll need to prepare:
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- Publicly accessible salary ranges by role and job level
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- Breakdown of bonuses, benefits, and all remuneration
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- Diversity statistics (gender, race, job category)
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- Methodologies or criteria for determining compensation
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- Workforce composition data
Transparency applies not just internally – salary and pay gap data will be published for employees and the public.
How Do You Collect and Report Pay Transparency Data in Brazil?
Most companies rely on HR information systems (HRIS), payroll software, and standardised data templates to collect, verify, and organise reporting data. Regular audits and cross-functional collaboration are key. Review data for completeness, accuracy, and any unexplained pay gaps before submission.
How Often Must Companies Update Pay Transparency Data?
Companies must update and publish pay transparency data at least annually, or as often as new regulations require. Watch for changes to reporting cycles as the law evolves, some updates may be required semi-annually or after major organisational changes.
What Are the Steps to Prepare for Brazil’s Pay Transparency Reporting?
1. Audit Your Pay Data
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- Collect compensation data (salary, bonuses, benefits)
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- Segment by job role, level, gender, and race
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- Identify pay gaps between similar roles
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- Document valid reasons for pay differences (e.g., tenure, performance)
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- Prepare action plans for unexplained gaps
According to SHRM, early audits let you fix issues before they’re public and before the Ministry calls.
2. Update Internal Policies
Your salary bands, promotion criteria, and performance review processes must be clear, consistent, and defensible. Every pay decision should have documented reasoning to withstand scrutiny.
3. Assign Compliance Ownership
Compliance is cross-functional:
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- HR gathers and validates the data
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- Legal ensures policies align with the law
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- Leadership approves action plans and maintains oversight
Many companies are setting up permanent compliance task forces to ensure nothing slips through the cracks.
4. Train Staff for Ongoing Compliance
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- Provide compliance training to HR, managers, and payroll staff
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- Use checklists and guides for annual or semi-annual reporting cycles
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- Schedule regular policy refreshers and documentation reviews
A culture of compliance starts with knowledge and accountability at every level.
What Are the Penalties for Non-Compliance with Brazil’s Pay Transparency Law?
The penalties under Brazil’s pay transparency law are significant:
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- Fines starting at R$10 million for failing to report
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- Up to R$50 million for LGPD privacy breaches
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- Public disclosure of non-compliance by the Ministry of Labour
How Can Companies Avoid Penalties?
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- Conduct proactive pay equity audits and correct gaps early
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- Implement clear, transparent pay policies and processes
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- Consult with legal, HR, and payroll experts on compliance strategy
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- Use compliance software for reporting and documentation
Non-compliance is just one regulatory risk. Our Expand Your Business in Brazil country guide outlines all the HR, payroll, and legal safeguards you should have in place to avoid fines and reputational fallout.
Why Pay Transparency Is a Business Opportunity
Brazil’s pay transparency mandate isn’t just another compliance hurdle. According to Harvard Business Review forward-thinking companies are leveraging these laws to unlock business value:
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- 23% improvement in employee retention
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- 31% faster time-to-hire
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- 40% reduction in gender pay gap litigation risks
The result? Millions saved, a stronger employer brand, and a decisive edge in Brazil’s competitive talent market.
For more on hiring, payroll, and compliance requirements in Brazil, see our Expand in Brazil guide.
What Are Leading Practices from Global Companies?
Learn from multinationals and industry leaders:
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- Benchmark pay practices globally, not just locally
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- Use third-party audits to identify and close gaps
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- Publish transparent pay frameworks to foster trust with employees and candidates
Why Agile HRO Is Your Compliance Partner for Brazil’s Pay Transparency Law
Meeting Brazil’s pay transparency requirements isn’t just about knowing the rules, it’s about having the right systems, processes, and expertise in place to get it right, every time. That’s where Agile HRO comes in.
We combine local compliance expertise, best-in-class HR and payroll technology, and hands-on support to help companies meet reporting requirements without adding internal strain.
How Agile HRO Helps You Stay Compliant
End-to-End Compliance Support: We manage the entire reporting cycle, from data collection to final submission.
Integrated HR & Payroll Solutions: Through our partnerships with leading platforms in Brazil, we deliver:
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- Custom pay band and diversity reporting
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- Audit trails and secure document management
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- Seamless integration with your payroll and HRIS data
Local Legal & Policy Guidance: Our in-country experts ensure your pay policies, salary structures, and documentation meet Brazil’s legal requirements and LGPD standards.
Ongoing Monitoring: We track legislative updates, so you never miss a deadline or requirement change.
Complying with Brazil’s pay transparency law is just one piece of the puzzle when operating in this fast-growing market. From payroll and HR compliance to hiring strategies and tax considerations, there’s much more to get right.
Discover everything you need to expand, hire, and operate successfully in Brazil with our Expand in Brazil country guide, your complete roadmap to navigating local laws, building a compliant workforce, and unlocking growth opportunities.
FAQs
1. Who must comply with Brazil’s pay transparency law?
Any company local or multinational with 100 or more employees in Brazil must comply, including those hiring through subsidiaries, branches, or Employer of Record (EOR) providers. The 100-employee threshold counts all staff (full-time, part-time, and contracted under direct management).
2. What information needs to be reported under Brazil’s pay transparency law?
Employers must disclose salary ranges, total remuneration, benefits, diversity data (gender, race, job category), and the criteria for pay decisions. This data must be organized by job role and level and made publicly accessible.
3. What are the penalties for non-compliance with Brazil’s pay transparency requirements?
Fines start at R$10 million for reporting failures and can reach R$50 million for data privacy breaches under Brazil’s LGPD. Non-compliance may also result in public reporting of violations and mandatory corrective actions.
4. How often must companies update their pay transparency reports in Brazil?
Currently, companies must publish data at least annually, though some updates may be required semi-annually or after significant organizational changes. Employers should monitor evolving Ministry of Labor requirements.
5. What steps can companies take to prepare for Brazil’s pay transparency reporting?
To prepare for Brazil’s pay transparency reporting, companies should audit pay equity, update salary structures and policies, assign a cross-functional compliance team, and use HRIS/payroll systems with built-in reporting and audit trails to ensure accuracy and compliance.