Direct Request (CEACR) - adopted 2025, published 114th ILC session (2026)

Finland

Equal Remuneration Convention, 1951 (No. 100) (Ratification: 1963)
Discrimination (Employment and Occupation) Convention, 1958 (No. 111) (Ratification: 1970)
Workers with Family Responsibilities Convention, 1981 (No. 156) (Ratification: 1983)

In order to provide a comprehensive view of the issues relating to the application of ratified Conventions on equality, the Committee considers it appropriate to examine the Conventions Nos 100 (equal remuneration), 111 (discrimination in employment and occupation) and 156 (workers with family responsibilities) together.

The Committee notes the observations of the Central Organisation of Finnish Trade Unions (SAK), the Confederation of Unions for Professional and Managerial Staff in Finland (Akava) and the Finnish Confederation of Professionals (STTK), and of the Federation of Finnish enterprises (SY) and the Confederation of Finnish Industries (EK), communicated with the Government’s report.

Part I. Conventions Nos 100 and 111

Convention No. 111 – National policy to promote equality of opportunity and treatment in respect of employment and occupation

Articles 1(1)(a), 2 and 3(b). Legislation. Prohibited grounds of discrimination. The Committee notes with interest the Government’s adoption of the Act on Legal Recognition of Gender (on the basis of Government Proposal 189/2022) on 3 April 2023, which separated legal recognition from medical examinations and abolished the previous infertility requirement, as well as the development of an Action Plan for Gender Equality 2024–27, which foresees a system-wide development programme to support and monitor equality and non-discrimination plans across the education system. The Committee asks the Government to continue providing information on the practical application of the Act on Legal Recognition of Gender (Government Proposal 189/2022), as well as on results achieved under the Government Action Plan for Gender Equality 2024–27.

Article 2. Measures to promote gender equality. Education and occupational segregation. The Committee notes the Government’s indication that, in line with the European Union Women on Boards Directive (2022/2381)’s goal of least 40 per cent of the under-represented sex on boards by 30 June 2026, women accounted in 2024 for 42 per cent of board members and 39 per cent of senior management in state-owned companies. The Committee also notes with interest the Government’s indication that gender equality planning obligations now apply to all educational institutions and Early Childhood Education and Care centres (ECEC), with unit-specific obligations for the latter since June 2023, and that equality plans must be updated regularly. It notes the joint project “Dismantling segregation – tools for a more equal working life” (2021–23), which developed practical tools and regional cooperation networks to reduce gender-based segregation. The Committee further notes the United Nations Committee on the Elimination of Discrimination against Women (CEDAW)’s concerns regarding persistent gender segregation in education and the labour market, including women’s concentration in traditionally “female” sectors, under-representation in non-traditional fields and senior academic posts, and the persistent gender pay gap of about 16 per cent, which adversely affects women’s pension entitlements. (CEDAW/C/FIN/CO/8, 31 October 2022, paras 29 and 31). The Committee asks the Government to continue to provide information on the measures undertaken and envisaged to combat education and occupational segregation and the results achieved, including through the implementation of the Action Plan for Gender Equality 2024–2027.

Access to education and vocational training and access to employment and occupation of the Roma. National Policy on Roma. The Committee welcomes the 2023 adoption of the National Roma Policy (ROMPO 3, 2023–30) and its 2023–26 implementation plan, whose key objective is to promote Roma inclusion, participation and equality, and to combat discrimination by addressing anti-gypsyism. The Committee also notes that the European Commission against Racism and Intolerance (ECRI), in its sixth monitoring cycle report on Finland adopted on 1 July 2025, highlights that unemployment among Roma remains critically high, at an estimated 30 per cent, and despite rising educational levels, Roma continue to face persistent barriers to entering the labour market, including discrimination in labour market access. The Committee asks the Government to provide information on: (i) the implementation of the National Roma Policy 2023–30; and (ii) concrete measures taken to address Roma educational and occupational segregation and discrimination in employment and occupation, and their impact.

Access to traditional occupations of the Sámi people. The Committee notes the 10 October 2024 decision of the United Nations Committee on Economic, Social and Cultural Rights (CESCR) on three communications from members of the Kova-Labba Siida Sámi herding community concerning mining on their traditional territory without impact assessments or effective participation. It notes that the CESCR found this failure violated their territorial and resource rights, amounted to intersectional discrimination and undermined their traditional occupations and means of subsistence. The Committee requests the Government to indicate measures to combat discrimination against Sámi in education, employment and occupation, and results achieved.

Measures to combat racial and ethnic discrimination. Access to employment and occupation of the immigrant population. The Committee notes the Government’s statistics indicating sustained supervisory activity on discrimination at work in 2021–23, with hundreds of contacts and enforcement requests and around 1,800 inspections in 2023–24 concerning discrimination in the use of foreign labour and the monitoring of job advertisements. It notes that discrimination based on origin, language or nationality is most frequently detected in recruitment and in posting undertakings, and that irregularities are common in employers’ equality-promotion obligations. The Committee further notes trade union concerns about continuing exploitation of foreign workers in low-paid, labour-intensive sectors and about enforcement challenges, including investigating underpayment, limited resources and tools, and the use of disguised entrepreneurship as a vector of exploitation. Furthermore, the Committee notes that, according to the European Union Agency for Fundamental Rights’ report Being Black in the EU (October 2023), respondents of African descent in Finland reported the highest rate of racist harassment among the 13 EU Member States surveyed. It also notes a 2025 study by the Ministry of Economic Affairs and Employment on the impact of foreign background on job-seeking, which identified clear ethnic discrimination against applicants with Iraqi, Somali and Russian backgrounds. The Committee asks the Government to indicate measures taken or envisaged to: (i) combat racial and ethnic discrimination and the exploitation of migrant workers; (ii) improve access to education and employment for persons with a foreign background; and (iii) raise awareness and strengthen training on non-discrimination and labour exploitation.

Convention No. 100 – Principle of equal remuneration for men and women for work of equal value

Articles 1 and 2. Equality plans and equal pay surveys. The Committee notes with interest the Government’s indication that the findings of the 2020 Study on Workplace Gender Equality Plans and Pay Surveys informed the Equal Pay Programme for 2024–37 and its Action Plan, which seek to improve the prevalence, coverage and quality of equality plans and pay surveys, including through step-by-step guidance and training. It further notes that, a Working Group preparing the transposition of the European Union Pay Transparency Directive (2023/970) has proposed amendments to the Equality Act introducing: (1) a statutory obligation on employers with at least 100 employees to report gender pay gaps and carry out joint pay assessments with personnel representatives; and (2) a general requirement that all employers have a pay system ensuring equal pay for equal work and work of equal value, with these amendments expected to be submitted to Parliament in autumn 2025. At the same time, the Committee notes trade union concerns about persistent non-compliance with the Equality Act, particularly in the private sector, where pay surveys remain infrequent and of poor quality, personnel are not properly informed, staff representatives are not involved as required, and measures under the Equal Pay Programme are neither adequately monitored nor yet having significant impact; they recall the 2021–22 Work of Equal Value project’s recommendation that workplaces strengthen equality plans and related pay surveys. The Committee requests the Government to provide an update on the adoption and entry into force of the proposed amendments and to indicate measures taken or envisaged to address the concerns raised by the trade unions.

Article 2(2)(c). Collective agreements. The Committee notes the Government’s indication that no specific measures have been adopted to promote the inclusion in collective agreements of provisions on equal remuneration for men and women for work of equal value, or to remove discriminatory clauses. It notes reliance on the general prohibition of gender-based pay discrimination in the Equality Act, on encouraging social partners to address the issue in bargaining, and on the Equal Pay Programme 2024–27, which invites private sector unions to participate in equal-pay measures. The Committee further notes that gender-impact assessments suggest direct discrimination in collective agreements is rare, but that indirect discrimination and non-equal remuneration for work of equal value are likely embedded in pay systems, as reflected in the social partners’ 2021 recommendation. It also notes trade union calls for stronger efforts to engage the parties to collective agreements in the Equal Pay Programme. The Committee asks the Government to report on collective agreements, if any, which include provisions on equal remuneration for men and women for work of equal value or where discriminatory clauses have been removed.

Article 3. Objective job evaluation. The Committee notes the Government’s information that, there is no national job evaluation system. It indicates that various models are used in collective agreements and that analytical systems are considered most suitable for identifying work of equal value, while title- or duty-based systems are least suitable. It further notes that, in the context of implementing the EU Pay Transparency Directive, the Working Group has proposed measures to provide employers with analytical, gender-neutral job-evaluation tools and that a related study is planned. The Committee asks the Government to: (i) report on progress in implementing the Directive; and (ii) indicate the status, results and impact of the planned study on gender-neutral job evaluations.

Part II. Convention No. 156

Articles 1(3) and 4. Other members of the family. Leave entitlement. The Committee notes the 2022 family leave reform and, in particular, the introduction in section 7(b) of the Employment Contracts Act (32/2022) of non-remunerated “family carers’ leave”, entitling workers to up to five days per year to care for a loved one other than a dependent child, in line with the EU Work–Life Balance Directive (2019/1158). The Committee notes the absence of information on any court or tribunal decisions interpreting section 7(a), including the justifications accepted for refusing requests for temporary absence for compelling family reasons and the circumstances constituting a “justifiable reason” to require an earlier return to work. It also notes the lack of information on measures to collect sex-disaggregated statistics on requests for and granting of leave to care for persons other than dependent children. The Committee asks the Government to: (i) provide information on relevant case law and clarify how “justifiable reason” is understood in law and practice; and (ii) indicate if any measures have been taken or envisaged to collect and analyse sex-disaggregated data on the use of leave under sections 7(a) and 7(b).

Article 4(b). Equality of opportunity and treatment in conditions of employment and social security. The Committee notes the Government’s information that the Working Group on Family Leaves and Gender Equality in Working Life proposed, inter alia, a comprehensive study on developing allowance systems and more equally distributing employers’ family-leave costs, alongside a review of the Equality Act. It also notes that, following the Action Plan for Gender Equality 2016–19, a family-leave compensation of €2,500 per case was introduced for employers of women, covering some 17,500–21,600 employees annually between 2018 and 2024, with outlays of €44–54 million (paid to 4,040 employers in 2024). The Committee further notes the Government’s statement that compensation has been concentrated on highly educated women aged 30–39 in administrative, clerical, managerial and professional occupations, with lower coverage in other service and sales occupations, and that in monetary terms payments have focused on larger municipal and private employers in health and social services and wholesale and retail trade, while expenditure remains clearly below the originally estimated €75 million. The Committee asks the Government to continue to provide information on measures to compensate employers for costs incurred, including under the Action Plan for Gender Equality 2024–27, and on steps taken to ensure that these costs do not perpetuate occupational segregation, as well as on the results achieved.

Flexible work arrangements. The Committee notes the Government’s information on flexible care allowance (for children under 3), partial care allowance (for children in the first and second years of school), part-time parental leave and the new unpaid family carers’ leave of up to five days per year. It notes evaluation findings of modest overall employment effects, stronger increases in part-time work among low-educated, low-income and single mothers, as well as an increase in fathers’ share of compensated parental-allowance days to 20.9 per cent in 2024, while overall use of part-time parental leave remains very low (3 per cent of parents) and national monitoring indicates that new flexibility options are still underused. The Committee also notes Trade Unions’ concerns that statutory limits on splitting leave may restrict take-up, including by fathers. It further notes the concern of the CEDAW that transition to telework risks further reinforcing occupational segregation. (CEDAW/C/FIN/CO/8, para. 31). The Committee asks the Government to continue to provide information on how these flexible work arrangements, including any telework or remote work options, contribute to the reconciliation of work and family responsibilities for women and men, together with available sex-disaggregated statistics on applications, approvals and refusals and any measures taken to promote their use among under-represented groups.

Conventions Nos   100, 111, 156 – Application in practice

Enforcement. The Committee notes with interest the Government’s description of the enforcement framework (Ombudsman for Equality, Non-Discrimination Ombudsman, National Non-Discrimination and Equality Tribunal and OSH authorities) and recent reforms, including the statutory pay-survey obligation, transposition of the EU Pay Transparency Directive, the 1 June 2023 amendments to the Non-Discrimination Act expanding the Non-Discrimination Ombudsman’s competence in working life, the clarification of OSH enforcement powers and 2023 OSH Act amendments, as well as the 2024 ratification of Convention No. 190 and the 2025 amendment to the Act on the Mediation of Labour Disputes. The Committee notes the absence of statistics on complaints, investigations and decisions concerning equal remuneration, and of detailed measures to strengthen labour-inspection monitoring of sex-based pay discrimination. The Committee further notes trade union observations that effective measures and systematic monitoring remain lacking, that sanctions for pay discrimination and non-compliance with the Equality Act and future pay-transparency framework are not sufficiently dissuasive, and that lengthy, complex procedures and limited resources for the Ombudsman for Equality hinder effective protection. Recalling the need for effective sanctions, remedies and institutional capacity, the Committee asks the Government to provide information on: (i) the adoption and content of the proposed Equality Act amendments on enforcement, sanctions and pay-transparency breaches; (ii) how recent reforms (including the Non-Discrimination Act, and OSH amendments have reinforced labour-inspection monitoring; and (iii) available data (by ground of discrimination, sex and sector), on complaints, investigations, decisions, sanctions and remedies concerning equal remuneration for work of equal value and discrimination in employment.