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Countries in which employees earn less than the applicable adequate wage benchmark

Revised ESRS 2026

ESRS Standard

29. The undertaking shall disclose whether or not its employees are paid an adequate wage and the benchmark or benchmarks it uses to determine adequate wages with an indication of the countries for which a given benchmark is used. If employees are not paid an adequate wage, the undertaking shall disclose the countries and the percentage of employees concerned.


Application Requirements

AR 20. The adequate wage benchmark used for comparison

with the lowest wage shall not be lower

than:

  • (a) in the EU: the wage level established through collective bargaining or the statutory minimum wage set in accordance with Directive (EU) 2022/2041 of the European Parliament and of the Council on adequate minimum wages in the EU;

  • (b) outside of the EU: the adequate minimum wage, established by legislation or collective bargaining, which provides a decent standard of living taking into account the ILO principles on estimating a living wage as a minimum level (without prejudice to higher standards of adequacy of wage); or

    • i. any living wage estimate, including estimates produced by ILO or an institution mandated by the public authorities of the country where the workers are based, which takes into account the ILO principles on estimating a living wage.


This article has been machine translated. In case of errors, please contact [email protected].

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