Is job evaluation required by law in New Zealand?

What New Zealand's law requires

New Zealand's Equal Pay Act 1972 is one of the older equal pay statutes in the world, and one of the most actively amended. The Equal Pay Amendment Act 2020 built a structured pay equity claims process for female-dominated occupations, and the Equal Pay Amendment Act 2025 — passed under parliamentary urgency on 5–6 May 2025 — substantially rewrote it.

The analytical core survived both amendments and is the reason New Zealand sits in the explicit tier: when a pay equity claim is assessed, the statute itself names the factors. The work must be examined for its skills, responsibilities, the experience required, the conditions of work, and the degrees of effort involved, and compared against appropriate male-dominated comparator work. That is factor-based job evaluation written into primary legislation — scoped to the claims process rather than imposed as a standing duty on every employer.

Who must comply

Any employer can face a pay equity claim, but the 2025 amendments raised the entry bar considerably:

• the work must be performed by at least 70% female employees (up from 60%), and must have been so for at least 10 consecutive years;
• claimants must show reasonable grounds, with evidence, that the work is historically and currently undervalued;
• comparisons follow a strict comparator hierarchy, prioritizing comparators within the same employer or sector before reaching outward.

The 2025 Act also discontinued all 33 pay equity claims that were in progress — including large claims across the care economy — requiring claimants to start again under the new tests. The change triggered nationwide protests and remains politically contested, so further amendment risk is real.

Enforcement and recent developments

Pay equity claims are bargained between the parties, with the Employment Relations Authority available when bargaining fails; settled claims have historically produced significant pay corrections in female-dominated public-sector workforces (care and support workers, teacher aides, social workers). The practical effect of the May 2025 amendment is that fewer claims qualify, and those that do face a heavier evidential burden — older online summaries describing the 2020 regime's 60% threshold and the pre-2025 claims are now out of date.

For employers, the regime's reactive design cuts both ways: there is no annual filing, but a qualifying claim arrives with statutory factor comparisons attached, and the employer's job documentation is immediately in play.

How point-factor job evaluation supports compliance

New Zealand's claims process is, in substance, an adversarial job evaluation — and the side with the better-documented factor analysis starts ahead:

• Claim-ready job information — a maintained point-factor evaluation already records each role's skills, responsibilities, effort, experience demands, and working conditions: the statute's exact assessment dimensions.
• Comparator analysis — the post-2025 comparator hierarchy makes within-employer comparators primary. Employers who can show factor-scored relativities across their own workforce can engage a claim on evidence rather than assertion.
• Undervaluation testing — the new "historically and currently undervalued" requirement turns on whether pay tracks job value. A factor-based ranking against pay is the cleanest way to test — or rebut — that proposition.
• Settlement durability — settled claims must be maintained; a documented methodology keeps agreed relativities stable as roles evolve.

New Zealand employers don't need job evaluation until the day they very much do. Building the factor documentation before a claim lands is considerably cheaper than reconstructing it during one.

The law

Frequently asked questions

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