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The CEO Pay Ratio Rule

Since 2018, the SEC has required public companies to disclose the ratio of CEO compensation to median employee pay. Across the 209 companies in our database, the average pay ratio is 157:1. Here is how the rule works.

What Is the CEO Pay Ratio?

The CEO pay ratio compares the total annual compensation of the CEO to the total annual compensation of the company's median employee. A ratio of 300:1 means the CEO earns 300 times what the median worker earns.

This disclosure was mandated by Section 953(b) of the Dodd-Frank Act and implemented by the SEC's final rule adopted in 2015. Companies first reported pay ratios in proxy statements filed in 2018.

How Is the Median Employee Identified?

Companies must identify the median employee using a “consistently applied compensation measure” (CACM) across all employees worldwide, including part-time, seasonal, and temporary workers. Common approaches:

  • Total cash compensation (base salary + bonus) for all employees
  • W-2 box 5 wages (Medicare wages) for US employees, with international equivalents
  • Payroll records with adjustments for part-time status

Companies can exclude up to 5% of non-US employees from the calculation. They can also use statistical sampling and reasonable estimates. The median employee can remain the same for three years unless there is a significant change in the employee population.

Why Pay Ratios Vary So Much by Industry

Pay ratios range from under 50:1 to over 3,000:1 across public companies. The biggest driver is not CEO pay — it is the median employee's pay level:

Retail & HospitalityPart-time workers, low median pay → High ratios (500-3000:1)
TechnologyHighly paid engineers → Lower ratios (50-300:1)
Financial ServicesHigher base salaries → Moderate ratios (100-400:1)
HealthcareMix of clinical and support staff → Wide range (100-1000:1)

Limitations of the Pay Ratio

While the pay ratio provides a useful data point, it has significant limitations:

  • Not comparable across companies. Different industries, geographies, and business models make direct comparisons misleading. A tech company with 5,000 engineers will have a lower ratio than a retailer with 200,000 part-time employees, regardless of how much the CEO is paid.
  • Methodology differences. Companies have discretion in choosing the CACM, excluding workers, and applying adjustments. Two identical companies could report different ratios.
  • Doesn't capture the full picture. A CEO with a low pay ratio might still be overpaid relative to performance. A CEO with a high ratio might be leading a high-performing company with a large hourly workforce.

How We Use Pay Ratio in Our Scoring

The CEO-to-worker pay ratio is one of four factors in our Pay-for-Performance Score, weighted at 10%. Rather than penalizing high ratios in absolute terms, we compare each CEO's ratio to their industry peer group average. A CEO whose ratio is well below their peers scores higher; one significantly above scores lower.

This approach accounts for industry differences while still rewarding companies that pay workers more generously relative to their sector. See our worst pay ratio rankings and best pay-for-performance rankings for details.

Further Reading