CEO Pay Ratio

Here’s a resource center for HR, finance, and accounting professionals who want to get on top of Dodd-Frank CEO pay ratio disclosure rules.

The Dodd-Frank Wall Street Reform and Consumer Protection Act, which requires most public companies to regularly report the total annual compensation ratio of the CEO compared with the median employee, became law in 2010. Five years after that—on August 5, 2015—the SEC issued its final ruling. And so here we are.

On this page, you’ll find everything we’ve published on pay ratio. This includes tips for calculating and disclosing the pay ratio, as well as ways to overcome challenges we’ve seen our clients run into.

Need more? We’re here to help. Look into our pay ratio disclosure services or contact us directly.

CEO Pay Ratio Year 2: Retain or Revisit the Median Employee?

Josh Schaeffer and David Outlaw · 11/15/2018

The pay ratio rule is still with us. Here are the most material methodology decisions the majority of companies will face in the second year of disclosure.


Pay Ratio Results from the Field: Disclosures through April 30, 2018

Takis Makridis and David Outlaw  · 5/29/2018

We collected and analyzed over 1,600 CEO pay ratio filings to take the pulse of trends and best practices from the country’s first adopters of this new regulation.


Pay Ratio Disclosure: A Checklist of Key Considerations

David Outlaw and Takis Makridis · 12/12/2017

Download our checklist of the required disclosure content to guide your efforts in drafting your proxy disclosure.


CEO Pay Ratio: Using Analytics to Complete Your Story

David Outlaw and Josh Schaeffer · 10/7/2017

Having trouble conveying your CEO pay ratio to others, inside or outside your organization? Pay ratio analytics can tell the story behind the calculation.


What You Need to Know About the September 2017 SEC Pay Ratio Guidance

David Outlaw and Alec Katric · 10/11/2017

On September 21, 2017, the SEC released additional pay ratio guidance. The new guidance primarily reiterates and clarifies flexibility that the rule already allowed, with one substantial update. In this blog post, we go over the highlights of the interpretive guidance and updates to the Compliance and Disclosure Interpretations, and we discuss the ideas posed in the Department of Corporate Finance guidance regarding statistical sampling.


CEO Pay Ratio: 40 Frequently Asked Questions and Answers

Takis Makridis, Josh Schaeffer, PhD, David Outlaw, and Alec Katric · 9/10/2017

Weighing in at a whopping 294 pages, the CEO pay ratio rule is a mix of general principles and explicit guidance that leaves no shortage of questions. In this booklet, we share some of the common questions that have come up and offer insights that may prove relevant in the course of your preparation. Reserve your copy today.


CEO Pay Ratio: 15 Burning Questions Answered

Takis Makridis and David Outlaw · 8/29/2017

Join us for a question and answer session discussing the challenges associated with the new CEO pay ratio disclosure rule.


The SEC Reopened Comments to the Dodd-Frank Pay Ratio Rule. Here’s What the Public Said.

Josh Schaeffer and David Outlaw · 5/8/2017

On February 6, the SEC reopened the CEO pay ratio rule for a second comment cycle. We reviewed each comment letter and summarized the main trends here.


A Practitioner’s Guide to Pay Ratio Project Management

Josh Schaeffer and David Outlaw · 3/8/2017

In this implementation-oriented guide, we break down CEO pay ratio planning and execution into 10 steps and include a quick reference checklist to help steer your efforts.


The Destiny of Dodd-Frank’s Executive Compensation Provisions

Takis Makridis · 2/28/2017, updated on 6/13/2017

With the fate of Dodd-Frank up in the air, we take a look at the current state of the law, and analyze what could happen next.


CEO Pay Ratio is Here – How to Prepare

Takis Makridis · 11/16/2016

CEO pay ratio is sure to be one of the big challenges of 2017 for equity compensation professionals. In this webcast, we provide an overview of what you can do to prepare for calculating and disclosing the ratio.


Pay Ratio CDI: What You Need to Know

Takis Makridis, Alec Katric, and David Outlaw · 11/14/2016

In an effort to clarify aspects of its original pay ratio guidance, the SEC released additional Compliance and Disclosures Interpretations (CDI) on October 18, 2016, with 5 questions and corresponding answers. Read the CDI, as well as our perspective on it here.


You’re Missing Compensation Data for Your Pay Ratio Calculation. How Do You Find the Median Employee?

Josh Schaeffer · 10/14/2016

As companies prepare for the new CEO pay ratio disclosure requirement in 2017, many are running into the problem of missing employee data, especially in international jurisdictions.


Surfing the Coming Pay Ratio Wave with Confidence

Nathan O’Connor · 6/17/2016

View the slides from this presentation on pay ratio calculation methodology and contextualizing results in the proxy, delivered at the 2016 World at Work Conference in San Diego.


Q&A on New Regulations From the FASB and SEC

Takis Makridis · 5/12/2016

Get answers about how these updates will affect the 10-K, the proxy, the compensation committee, finance and accounting processes, and more.


Population Analysis: An Easier Way to Identify Median Employee Pay

Josh Schaeffer and Nathan O’Connor · 5/10/2016

In this April 2016 Workspan article, we explain why population analysis can beat sampling methods when disclosing your CEO pay ratio.


CEO Pay Ratio: An Update from the Field

Takis Makridis · 3/4/2016

Here’s what we’ve discovered between our own research, consulting with other experts, and helping companies develop their pay ratio calculations.


Dodd-Frank 5 Years On – The Adventure Continues

Nathan O’Connor · 3/4/2016

Download this on-demand webinar for an overview of where things stand plus a primer on specific Dodd-Frank rules.


How Many is Enough? Sample Selection and CEO Pay Ratio Accuracy

Josh Schaeffer and Therese Sebastian · 12/8/2015

Statistical sampling makes it too easy to fall short of meeting the burden of representational faithfulness in the SEC’s guidance.


A Five-Minute Guide to Pay Ratio Disclosures

Takis Makridis and Therese Sebastian · 8/5/2015

In this article, published before the SEC finalized its pay ratio disclosure rules, we argue that companies should consider the requirement an opportunity to add narrative and supplementary numerical color to their disclosures.



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