A Guide to the EU Pay Transparency Directive 2025 | Download our eGuide for free
Pay transparency, pay equity, and reporting requirements in South Africa
South Africa’s keystone pay equity legislation, the Employment Equity Act (EEA), dates back to 1998. The EEA established the nation’s legal standard for equal pay for work of equal value. For many individual employers, this means creating and abiding by an Employment Equity Plan and reporting related data annually.
Meanwhile, South Africa is currently at the threshold of major possible change in terms of pay transparency. In June 2025, the Build One South Africa (BOSA) party introduced the Fair Pay Bill into Parliament. This bill would enact key pay transparency measures with the goal of advancing equal opportunity and combating pay discrimination.
In this article, we’ll cover employers’ pay equity and reporting requirements under the EEA, then give an overview of the pay transparency measures that may come about if the Fair Pay Bill is passed.
Pay equity in South Africa: The EEA and reporting requirements
Employers covered by the EEA need to create and abide by an Employment Equity Plan for their organization. The overall goal is to identify and address any barriers to pay equity or advancement based not only on gender, but also race and disability status. As of 2023, these plans also have to align with employment equity targets, which are tailored to each economic sector and set by the Department of Employment and Labour.
An Employment Equity Plan includes:
- The employer’s objectives.
- Planned affirmative action measures.
- Plans to correct any identified areas of underrepresentation (including strategy, timeframe, and numerical targets).
- Plan duration (1-5 years).
- Timeline for each year, including non-numerical goals.
- Monitoring and evaluation procedures.
- Dispute resolution procedures.
- List of staff responsible for the plan.
Which employers need to follow these requirements?
The EEA applies to the following:
- Employers with 50 or more employees.
- Employers of any size (including fewer than 50 employees) that are “organs of state”.
- Employers of any size that are subject to certain collective agreements.
When and how do employers need to report?
The deadline for report submission is the first working day of October for hard copy forms but January 15th for forms submitted online.
If an employer surpasses the 50 employee mark after the first working day of April, it does not need to provide its first report until the following reporting cycle. However, if an employer surpasses the 150 employee mark, it does need to report for the current reporting cycle.
The reports
Reports are submitted in two forms: EEA2 and EEA4.
The EEA2 form focuses on demographic data, specifically gender, race, and disability status. It calls for recruitment, termination, and promotion data, all broken down by those demographics and by occupational levels. It also includes the employer’s numerical goals, identified barriers, and affirmative action measures, drawing from the Employment Equity Plan.
The EEA4 form delves into pay data, with the goal of identifying possible pay inequity. Employers need to be ready to provide the following:
- Total, fixed, and variable remuneration for the workforce, broken down by demographic groups (i.e., male/female, black/white, disabled/non-disabled) and occupational levels.
- Individual worker remuneration data for the highest- and lowest-earning employees in each demographic group and occupational level.
- Pay gap calculations by demographic group.
- Average annual remuneration for top 10% and bottom 10% of earners, as well as median remuneration.
- Vertical gap between the highest and lowest earner.
- Whether the Employment Equity Plan has measures to address the vertical gap.
- Reasons for any identified income differentials.
To help organizations gather this data, the South African government has provided official guidelines. These guidelines describe how the demographic categories and occupational levels are classified.
For more information on how PayAnalytics by beqom helps you create reports at the click of a button that are compliant with South Africa's legislation, reach out to book a personalized meeting.
Pay transparency in South Africa: Possible developments under the Fair Pay Bill
Proposed in summer 2025, the Fair Pay Bill would introduce measures similar to those included in the EU Pay Transparency Directive or those passed by some U.S. states and Canadian provincial governments. As of late 2025, the bill is still moving through the legislative process. If the bill is passed, here is what it would require of employers.
- Job postings would need to specify the position’s salary or salary range. The same applies for postings for promotions or transfers.
- Employers would be prohibited from asking about a candidate’s salary history.
- Employers would be required to maintain documentation on their pay structures.
- Employees would have the right to discuss their pay.
For in-depth resources and practical guides to pay transparency, see our complete handbook.
Further support with PayAnalytics by beqom
South Africa’s pay equity legislation and reporting requirements were implemented to motivate employers to take concrete action to close their demographic pay gaps. PayAnalytics by beqom enables automated pay audits so you can quickly identify those gaps within your organization and obtain the data necessary for the EE4 report.
Our system then generates suggestions for corrective action to help you close those gaps while optimizing for budget and time constraints. This helps your organization develop a data-informed, measurable, and efficient plan for closing its pay gaps.
We’re happy to talk to you about how PayAnalytics by beqom can integrate with your existing systems to deliver accurate and user-friendly analysis and reporting. Contact us today.
Connect with the author
