Read time: 6 mins
Based on Bridging disclosure and action: The role of intermediaries in gender pay gap regulation, published May 2025, by Sally Curtis, Jananie William, Anna von Reibnitz, Miriam Glennie, and Andreas Pekarek.
Reforms to Australia’s Workplace Gender Equality Act give the public new pay gap data. Intermediaries welcome the changes, but emphasise the law needs stronger compliance measures to drive real progress.
Read time: 6 mins
Based on Bridging disclosure and action: The role of intermediaries in gender pay gap regulation, published May 2025, by Sally Curtis, Jananie William, Anna von Reibnitz, Miriam Glennie, and Andreas Pekarek.
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Gender pay gaps stubbornly persist. On average, women are paid less than men. In Australia, the pay gap currently sits between approximately 12 and 22 per cent depending on the measure used.
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Intermediaries help make the law work. These intermediaries include investors, trade unions, advocacy groups, and researchers. They can use pay gap data to pressure employers, propose legal reforms, and mobilise public debate.
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Reform momentum is building. From 2026, large employers will also have to set targets and demonstrate progress, but effective enforcement beyond data disclosure will determine whether this closes the gap.
Since 2012, the Workplace Gender Equality Act has required employers to report their gender pay gaps to the regulator. Until 2024, only aggregated industry figures were made public.
Recent reforms mean organisation-level data is now published, alongside new requirements on sexual harassment, discrimination, and executive workforce reporting.
ANU and University of Melbourne researchers analysed 121 public submissions to the 2021 review of the Workplace Gender Equality Act (the Review) and conducted 14 in-depth interviews with key intermediaries. Key intermediaries act as a bridge between regulation and employers. Key intermediaries in gender equality include trade unions, investors, advocacy groups, and peak bodies.
Workers, who are most affected by unequal pay, often lack the power, resources, or organisational leverage to use disclosure data effectively. This makes the role of intermediaries essential in translating transparency into action.
The study found that intermediaries can:
In short, intermediaries turn numbers into accountability.
Gender pay gap policy has focused on disclosure to shine a light on inequalities. But intermediaries interviewed for the study stressed that disclosure alone is not enough to shift the entrenched gender pay gap. They say that disclosure without consequences is insufficient.
“If we are relying on (unpublicised disclosure) for a wholesale shift … well, it would have happened by now. And it hasn’t.” – Interviewee, investor group.
The 2024 reforms in Australia have taken a first step in closing the disclosure-action gap, by making the gender pay gap data disclosed by employers to the regulator available to the public. Comparative evidence supports disclosure. In the UK, employer-level disclosure mandates led to the biggest reductions in pay gaps where organisations were most exposed to public scrutiny.
Additionally, from 2026 large employers will need to set targets in areas including gender pay gaps and leadership diversity.
Despite these reforms, however, the gender pay gap remains stubborn and accountability gaps remain.
Intermediaries welcomed the 2024 reforms with 91% of Review submissions supporting improved transparency through public disclosure of employer gender pay gaps.
But they also called for stronger levers to make disclosure meaningful:
The ANU and University of Melbourne research suggests that to close the gender pay gap, policymakers should:
Without these measures, there is a risk of mistaking disclosure for progress and leaving the burden of enforcement to intermediaries alone.
“We’ll have pockets of progress, but sometimes you need to have something that’s just a mandatory regime with some real accountability, and penalties. Otherwise, [employers] can just get away with not doing it.” (Journalist)
