Salary Transparency: Companies with 100 or More Employees Must Update Information by August 31st

The deadline set by the Ministry of Labor and Employment (MTE) runs from August 3rd to 31st, on the Emprega Brasil Portal. The data will feed into the 6th Salary Transparency and Remuneration Criteria Report, the first prepared after the validation of the Salary Equality Law by the Supreme Federal Court (STF).

The Ministry of Labor and Employment (MTE) opened, on August 3rd, the period for employers with 100 or more employees to update the information that will make up the 6th Salary Transparency and Remuneration Criteria Report. Completion is mandatory, the deadline is August 31st, and submission must be done exclusively through the employer's area on the Emprega Brasil Portal.

The semi-annual report is one of the main obligations created by Law No. 14,611/2023, known as the Equal Pay Law, regulated by Decree No. 11,795/2023 and by MTE Ordinance No. 3,714/2023. The objective of the law is to provide transparency to remuneration practices and promote equal pay between women and men.

What information should be provided and the 6th Edition Cycle

At this stage, companies need to report the criteria they use to remunerate their employees, the actions aimed at promoting diversity, such as hiring and promotion policies for women and underrepresented groups, and initiatives to support family and parenthood.

Here's an important warning: according to the Brazilian Ministry of Labor and Employment (MTE), only information submitted through the Emprega Brasil Portal within the deadline will be considered in the preparation of the 6th edition. This supplementary data will be cross-referenced with information already available in official databases, such as eSocial, to generate an individualized report for each establishment.

According to the six-month cycle defined in Decree No. 11,795/2023, the expectation is that the Ministry of Labor and Employment (MTE) will make the 6th edition of the report available in September. From then on, it will be up to the companies to publish their individualized reports on websites, social networks or similar channels, in a way that is visible to employees and the general public.

The Consolidation of Law in the Supreme Federal Court and the End of Preliminary Injunctions

This is the first update cycle after the Supreme Federal Court ruled on the lawsuits challenging the Equal Pay Law (ADI 7612, ADI 7631 and ADC 92, reported by Minister Alexandre de Moraes). In May 2026, the Plenary validated the rule and confirmed the requirement for companies with 100 or more employees to publish the reports, rejecting arguments of violation of the LGPD (Brazilian General Data Protection Law), business secrecy, and free enterprise.

In practice, the decision ends the strategy of seeking injunctions to avoid disclosing the report, a path some companies had been adopting. The obligation has become a definitive item on the labor compliance agenda. The context reinforces the relevance of the topic: the 5th edition, released in May, showed that women still receive, on average, 21.3% less than men in private companies with 100 or more employees. The number has remained practically unchanged since the policy began in 2023.

Penalties and Practical Impacts

Anyone who fails to publish the report is subject to an administrative fine of up to 31 times the payroll, limited to 100 minimum wages, without prejudice to the sanctions applicable to cases of wage discrimination (Article 5 of Law No. 14,611/2023). Furthermore, if wage inequality or remuneration criteria are found, the company must develop and implement an action plan to correct the problem, with goals and deadlines, ensuring the participation of union representatives and employees.

Therefore, before answering the questionnaire, it is worth reviewing the quality and consistency of the data registered in eSocial. Inconsistencies in CBO (Brazilian Classification of Occupations), job classifications, and compensation information distort the report's indicators and can generate unnecessary exposure. Answers regarding diversity, hiring, and parenting policies should also accurately reflect what the company actually practices, as generic or unsubstantiated statements may be questioned during audits and potential legal proceedings.

Finally, it is wise to prepare the communication for the September release now, anticipating how the indicators will be interpreted by internal audiences, unions, and the market. Documenting the compensation criteria used also helps, as this organization strengthens the company's defense in discussions about salary equalization and discrimination.