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

Estonia

Equal Remuneration Convention, 1951 (No. 100) (Ratification: 1996)
Discrimination (Employment and Occupation) Convention, 1958 (No. 111) (Ratification: 2005)

Other comments on C100

Other comments on C111

Observation
  1. 2025
  2. 2023
Direct Request
  1. 2025
  2. 2023
  3. 2016
  4. 2012
  5. 2010
  6. 2008

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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) and 111 (discrimination in employment and occupation) together.

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

Article 1(1)(b). Other prohibited grounds of discrimination. Persons with disabilities. The Committee notes the measures adopted by the Government to support the education, training and employment of persons with disabilities. According to the Social Insurance Board, 102,863 persons with disabilities lived in the country in 2025. The Government reports that, in 2024, 33 per cent of persons with reduced work ability (aged 20–64) participated in lifelong learning and, and that among these persons the employment rate was 53 per cent. However, according to the 2025 report entitled Country Report: Non-discrimination of the European Network of legal experts in gender equality and non-discrimination of the European Commission, unemployment remains the key social issue: only 26 per cent of all persons with disabilities (aged 15–74) were employed in 2023, compared with 72 per cent of persons without disabilities. Regarding complaints, the Government indicates that labour dispute bodies do not collect disability-specific data. The Gender Equality and Equal Treatment Commissioner handled 21 disability-related enquiries in 2024, and the Labour Inspectorate identified two bullying cases related to disability over the past five years. The Committee asks the Government to provide:(i) information on measures adopted to address the remaining barriers persons with disabilities face in accessing training and employment in both the public and private sectors, as well as any assessment made of the impact of these measures;and (ii) updated data on the employment rates of persons with disabilities, disaggregated by sex, both in the public and private sectors.
Sexual harassment and other forms of harassment. Violence at work. The Committee notes that Article 11(1)(4) of the Gender Equality Act requires employers to ensure protection from gender-based harassment and sexual harassment in the working environment. It further notes the concerns of the United Nations (UN) Committee on the Elimination of Discrimination against Women (CEDAW), in its 2024 concluding observations, regarding the high incidence of sexual harassment in the workplace and the prevalence of online violence and harassment against women in political and public life (CEDAW/C/EST/CO/7, 6 June 2024, paras 25 (d) and 31 (e)). The Committee asks the Government to provide information on: (i) the measures taken to prevent and address sexual harassment in the workplace, in particular by raising awareness of article 11(1)(4) of the Gender Equality Act; and (ii) any cases of sexual harassment or violence at work and in occupation addressed by labour inspectors, courts or other competent authorities, as well as penalties imposed and compensation awarded.
Articles 2 and 3. Equality of opportunity and treatment irrespective of race, colour or national extraction. Roma people. The Committee notes the information provided by the Government on the measures taken to support Roma inclusion under Cohesive Estonia 2030 and related plans and welcomes initiatives such as training programmes and the establishment of the Roma Youth Centre in Valga with mentoring services. It also notes the data provided by the Government, including a 17.4 per cent employment rate for Roma aged 15–74 in 2024; education figures showing 60 Roma pupils in general education (44 studying in regular classes and 16 in special classes) and eight in early education; and the 2021 Census finding that 676 Roma people live in Estonia. The Committee asks the Government to: (i) continue to report on the new measures adopted, under Cohesive Estonia 2030 and related development plans, to promote equality of opportunity and treatment for Roma; and (ii) monitor the impact of its efforts to tackle discrimination against these groups. It also asks the Government to report on the participation of Roma, as well as other minority women, in education, training and employment promotion opportunities.
Equality of opportunity and treatment between men and women. The Committee notes that, according to the Labour Force Survey (2022–2024), the employment rate of women remained stable at 67 per cent between 2022 and 2024; but continued to be lower than that of men (71–72 per cent). Furthermore, occupational segregation persists: in 2024, men were significantly overrepresented in “craft and related trades workers” (24.7 per cent of employed men were involved such trade, compared to 3.4 per cent of women) and “plant and machine operators and assemblers” (15.3 per cent compared with 4.5 per cent of women), while women were more concentrated in “clerical support” (8.7 per cent of women compared to 4.9 per cent of men) and “service and sales workers” (19.5 per cent compared to 5.7 per cent of men) occupations. Women also remained under-represented in managerial positions (5.8 per cent compared to 8.9 per cent of men). The Committee further notes the Government’s efforts under the Welfare Development Plan 2023–30, implemented through four-year rolling programmes. Nevertheless, it notes the CEDAW’s concerns about: (1) the limited effectiveness of existing gender equality strategies; (2) women’s severe under-representation in managerial roles, digital governance, artificial intelligence, and entrepreneurship; and (3) the lack of measures to support women’s reintegration into the labour market after periods of unpaid care work. (CEDAW/C/EST/CO/7, paras 15(a), 31(b) and (d), and 35(a)). The Committee asks the Government to provide information on the measures taken or envisaged in order to address vertical and horizontal gender segregation in the labour market, including by promoting women’s participation in non-traditional fields of study and professions, and through addressing negative gender stereotypes surrounding the roles and aspirations of men and women in the society. It also asks the Government to provide information on: (i) the concrete measures taken and the results achieved under the Welfare Development Plan 2023–30 and any evaluation undertaken on its implementation; and (ii) statistics on the distribution of men and women, disaggregated by economic sector and occupation, both in the public and private sectors.

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

Articles 1 to 4. Gender pay gap. The Government indicates that the gender pay gap continued to decline, reaching 13.1 per cent in 2023 and 13.2 per cent in 2024. Furthermore, according to Statistics Estonia, substantial sectoral gender pay gaps remained in 2024, including in financial and insurance activities (25.5 per cent), information and communication (24.4 per cent), wholesale and retail trade (23.5 per cent), human health and social work (20.7 per cent), and manufacturing (20.2 per cent). Conversely, women earned more than men only in transportation and storage, resulting in negative gender pay gap of 7.1 per cent. The Committee notes the Government’s reference to the Organization for Economic Co-operation and Development (OECD) findings that firm-level pay practices account for about half of the unadjusted gender pay gap, largely due to women’s concentration in lower-paying firms. The Committee notes that the Government has not provided information on concrete measures to address these underlying causes, including under the Welfare Development Plan 2023–30. The Committee asks the Government to intensify its efforts to effectively reduce the persistent gender pay gap and address its root causes, such as occupational gender segregation and gender stereotypes. It again asks information on: (i) specific measures and outcomes of activities undertaken in this regard, particularly within the framework of the Welfare Development Plan 2023–2030; and (ii) data on the earnings of men and women, disaggregated by economic activity and occupation, both in the public and private sectors.
Measures to promote equal remuneration. Pay transparency. The Committee notes that the Government is preparing draft legislation to transpose the Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms (hereinafter “EU Pay Transparency Directive”). According to the Government, the forthcoming legislation will: (1) require employers to establish pay structures based on objective and gender-neutral criteria; (2) oblige employers to inform job applicants of pay levels or ranges before interviews; (3) grant workers the right to obtain information on average pay levels and gender pay gaps for those performing the same work or work of equal value; and (4) introduce gender pay gap reporting obligations, based on administrative data, for employers with at least 100 employees. The Committee asks the Government to provide updated information on the progress made in adopting legislative measures to strengthen pay transparency in the context of the transposition of the EU Pay Transparency Directive.
Article 3. Tools for the assessment of the gender pay gap and objective job evaluation. The Committee notes the Government’s indication that the digital pay gap tool “Pay Mirror” was launched in 2024 to help employers (with at least three men and three women) to identify gender pay gaps, including through indicators on average and median pay, pay quartiles, occupation-based comparisons and irregular pay. The Government adds that around 400 employers use the tool each month. The Committee also notes the ongoing PALK project to develop a voluntary job evaluation methodology and related guidance and training. In this regard, the Committee notes that, while Article 63 of the Civil Service Act establishes procedures and salary guides for determining salary components in the public sector, there are no equivalent legal criteria for determining work of the same or equal value in the private sector. In light of the persistent gender pay gap, the Committee asks the Government to provide information on: (i) the method and criteria currently used in the public sector to classify and rank jobs and positions; (ii) the implementation of the tool “Pay Mirror”, the results achieved at the workplace level, and its impact on the reduction of the gender pay gap; and (iii) any other steps taken to develop and implement objective job evaluation in the private sector and the results thereof.
Articles 2(2)(c) and 4. Collective agreements and cooperation with employers’ and workers’ organizations. The Committee notes the Government’s indication of the various activities undertaken by the Ministry of Economic Affairs and Communications to address occupational segregation, including training and awareness-raising on gender stereotypes. The Government also refers to public awareness activities on the gender pay gap, such as the observance of Equal Pay Day. While welcoming these initiatives, the Committee observes that the Government does not provide information on any actions undertaken in cooperation with employers’ and workers’ organizations, nor on any collective agreements containing provisions on equal remuneration for work of equal value. The Committee once again requests the Government to provide information on: (i) collective agreements in force containing clauses providing for equal remuneration for men and women for work of equal value, as well as the content of these clauses; and (ii) any actions undertaken, in cooperation with the social partners, to promote this principle. The Committee also asks the Government to provide information on any assessment of the impact of the above measures on the evolution of the gender pay gap in the country.

Conventions Nos   100 and 111 – Application in practice

Enforcement. Access to justice. The Committee notes the Government’s indication that the number of enquiries received by the Gender Equality and Equal Treatment Commissioner (GET), increased from 198 in 2023 to 230 in 2024, mainly concerning gender, disability and ethnicity. While the Government considers this rise a sign of greater visibility and trust in the GET, it also acknowledges that many enquiries fall outside the GET’s mandate due to the limited scope of the protected grounds under the Equal Treatment Act. The Committee also notes the gradual increase in the GET’s budget and planned reforms to strengthen equality bodies. In this regard, the Committee observes from the Country Report: Non-discrimination of the European network of legal experts in gender equality and non-discrimination of the European Commission, that discrimination litigation remains very limited, notably due to fear of stigmatization, low awareness of rights, weak remedies, and inconsistent application of the burden of proof. Further, the Committee notes the Government’s indication that labour inspectors do not yet supervise equal pay compliance and that no authority maintains specific statistics on gender pay dispute cases. Noting the low levels of reporting, the Committee asks the Government to provide information on: (i) the efforts made to build the capacity of labour inspectors, judges, and other relevant authorities with a view to enable them to detect discrimination and unequal pay cases and to impose dissuasive penalties; (ii) any awareness-raising measures to ensure that workers, employers and their organizations are informed of their rights and of available complaint mechanisms; and (iii) the number and nature of discrimination and gender pay inequality cases handled by labour inspectors, the GET, the Chancellor of Justice, the courts or any other competent authorities, including any sanctions imposed and remedies granted.
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