September 23, 2020
Legislative action is increasingly being used around the world to bring more women into the boardroom.
Looking at the actions of peer countries helps us better understand international progress on women’s representation. These trends and insights can inform the decisions Canadian leaders need to make.
This digital experience summarizes the available data on legislative approaches for increasing women’s representation on boards across all OECD countries—as well as the progress they’ve made to date.
Our data divide OECD countries using four main categories:
All on Board
Hard quotas
Target percentages for women’s representation on boards enacted through legislation that are binding and can have sanctions/penalties for non-compliance
Soft quotas
Recommended or voluntary targets determined by corporate governance codes, stock exchange listing rules, or other regulatory-supported authorities to encourage and increase the representation of women on boards. Though these are not quotas per se, we have simplified the terminology to contrast soft approaches against hard quotas.
No mandated activity
No quotas, targets, or disclosure requirements from legislation, corporate governance codes, or stock exchange listing rules.
Some countries use a combination of hard and soft quotas
to target specific sectors.
What we’re seeing
Quotas
Soft quotas are the most-used approach internationally: limited penalties, voluntary targets, and a reliance on stakeholder or public accountability and governance practices to increase the share of women on boards. Canada uses a soft but unique approach - publicly traded companies have to disclose women's representation but are not held to a specific target or quota. Companies are also asked to specify whether a target has been adopted, and an explanation if not, but does not recommend the adoption of a specific target.
Most countries take a soft approach to encourage representation
Sources: Deloitte; Piscopo and Muntean; The Conference Board of Canada.
(n = 36; percentage of countries)
Soft quotas: Average 26% of board members are women
Australia
Chile
Finland
Ireland
Luxembourg
Netherlands
New Zealand
Slovenia
Spain
Sweden
Switzerland
Turkey
United Kingdom
Canada: 18% of all board seats for companies covered by disclosure are women. For the largest 60 of these companies, women hold 30% of board seats
Hard quotas: Average 31% of board members are women
Denmark
France
Greece
Iceland
Israel
Norway
Portugal
Soft quotas
Hard quotas
Canada
There is still much variance in representation from country to country. Some countries have been able to reach at least 30 per cent representation with soft quotas while others have struggled. Similarly, Norway and France have achieved 30 per cent representation on all of their large boards with hard quotas, while progress has been slow for other countries with hard quotas, such as Greece and Israel.
There also seems to be little correlation between representation success and how long a quota has been in place. Greece and Israel have had initiatives for about 20 years, but Greece has only seen a gain of 3.6 per cent and Israel has only gained 7.6 per cent. In contrast, Ireland had a 17.5 per cent increase in women on boards over 15 years. All three countries had representation levels below 15 per cent when quotas were put in place.
Germany, Austria, Italy, and Belgium are the only four OECD countries to use both soft and hard quotas: while most companies are subject
to a soft quota or voluntary targets, a subset are mandated by
hard quotas.
Nine OECD countries have no formal quotas or legislation in place. Instead, these countries have developed policies to encourage boards to recruit women, some more formalized than others. Currently, these nine countries average 14 per cent women on boards.
Critical mass at 30 per cent
Research shows that when at least three board positions or 30 per cent of board seats are filled by women, the boards’ culture becomes more inclusive of women.
Belgium, Italy, Portugal, and Norway have achieved critical mass on the boards of all their largest companies—and happen to rely primarily on hard quotas.
Forty per cent of Canada’s largest companies—companies on the S&P/TSX Composite Index—have achieved critical mass. Other countries are much further behind, and there is little consistency in their legislative approaches. Less than 16 per cent of the largest companies have reached critical mass in Poland (no quota) and Greece (hard quota), and less than 10 per cent in Chile and Japan (both soft quotas).
Share of major boards with at least 3 women
Japan
Soft quotas
Hard quotas
Canada
Among the 14 OECD countries that use soft quotas, 26 per cent of board members, on average, are women. However, the seven countries with hard quotas showed only a little more progress, averaging about 31 per cent.
Belgium
Italy
Portugal
Norway
Canada
Poland
Greece
Chile
Japan
Hard quota & soft quota
Hard quota & soft quota
Hard quota
Hard quota
Disclosure & hard quota in Quebec
No formal quotas or policies
Hard quota
Soft quota
Soft quota
100
100
100
100
63.0
15.8
14.3
5.9
3.4
Comply or explain
A “comply or explain” approach is used by 12 OECD countries, including Canada. This approach varies from country to country, but the intent is to encourage companies to be more diverse by being held to the accountability of shareholders and the public. Organizations share information about how many women are on their boards and their efforts to increase this representation, or explain why they choose not to. While Canada does use a comply or explain approach to disclosure requirements, comply or explain applies specifically to the disclosure of information, rather than compliance with a target, as in most comply or explain countries. (For more on comply or explain, see our project landing page, All on Board: Turning Evidence Into Action for Women’s Leadership.)
In all countries using comply or explain policies except Canada, this mechanism is tied to a specific nation-wide quota—though these quotas are necessarily soft due to the nature of comply or explain
(i.e., formal sanctions or penalties are not enforced for failure to
meet targets).
Of the 12 countries using comply or explain policies, seven have achieved 30 per cent representation on their largest boards: Austria, Australia, Germany, Finland, Belgium, Sweden, and the Netherlands.
See how progress in Canada compares with other countries that use comply or explain:
Countries using comply or explain legislation
The ongoing debate
Debate on the appropriateness and impact of soft, voluntary approaches versus hard quotas is ongoing. Supporters of soft quotas or comply or explain policies argue their approach effectively encourages gender diversity on boards while ensuring boards can still select members based on experience and skills, rather than to simply reach a target. On the other side, supporters of hard quotas argue that voluntary approaches provide “loopholes” for companies that disagree with mandated quotas.
This debate is also present within jurisdictions. Our closest peer country, the United States, has no national legislation for women on boards, but a growing number of states are using legislative action. California adopted a hard quota in 2018. Hard quotas are under consideration in Hawaii, Michigan, Massachusetts, New Jersey and Washington State while mandatory disclosure requirements have been enacted in Maryland, Illinois, and New York.
For detailed information on each country’s approach and progress, check out our interactive data table here
For detailed information on each country’s approach and progress, check out our interactive data table here
Bringing things back to Canada
The progress made with different legislative approaches is mixed and dependent on context—governance principles, social, cultural, and political contexts. Legislation effective in one region won’t necessarily have the same outcomes in all regions. There is also
a lack of rigorous country-specific research linking different approaches directly to progress.
What does this mean for Canada? Despite the challenges in comparison, we can still see what’s worked in peer countries and consider their potential in Canada.
More importantly, these data highlight the need for a Canadian-specific analysis of our own approach and progress. Canadian decision-makers need to know how well comply or explain policies are working—at home and abroad—so they can ensure the best approaches to increase representation are in place.
At The Conference Board of Canada, we are addressing this challenge by evaluating whether and how women are more represented on boards and the organizational practices and characteristics that matter most for this progress.
To learn more, check out our project page here
Click here to view our sources
Maria Giammarco
Nimi Pukulakatt
Senior Research Associate
Research Associate
Back to top
Get a deeper look into the debates around these approaches by reading our impact paper, All on Board: Turning Evidence Into Action for Women’s Leadership.
Sources: Deloitte; Piscopo and Muntean; The Conference Board of Canada.
Sources: Emelianova and Milhomem; The Conference Board of Canada
Different countries, different policies, different results
Note that country averages are impacted by the number of companies and size of companies included in each country’s reported results. For example, Australia and the UK report on their top companies and their average is thus inflated, whereas Canada’s average reflects all disclosure companies. When limited to the top companies (i.e., TSX60) representation reaches 30%.
Sources: Deloitte; Piscopo and Muntean; The Conference Board of Canada.
(percentage)
Disclosure
Requirements to report on board representation and/or the use of other activities to increase women’s representation. This is the approach used in Canada for publicly traded companies on the Toronto Stock Exchange (TSX).
All on Board:
Comparisons Around the World
Date goes here, 2020
Legislative action is increasingly being used around the world to bring more women into the boardroom.
Looking at the actions of peer countries helps us better understand international progress on women’s representation. These trends and insights can inform the decisions Canadian leaders need to make.
This digital experience summarizes the available data on legislative approaches for increasing women’s representation on boards across all OECD countries—as well as the progress they’ve made to date.
Some countries use a combination of hard and soft quotas to target specific sectors.
Hard quotas
Target percentages for women’s representation on boards enacted through legislation that are binding and can have sanctions/penalties for non-compliance.
Soft quotas
Recommended or voluntary targets determined by corporate governance codes, stock exchange listing rules, or other regulatory-supported authorities to encourage and increase the representation of women on boards. Though these are not quotas per se, we have simplified the terminology to contrast soft approaches against hard quotas.
Disclosure
Requirements to report on board representation and/or the use of other activities to increase women’s representation. This is the approach used in Canada for publicly traded companies on the Toronto Stock Exchange (TSX).
No mandated activity
No quotas, targets, or disclosure requirements from legislation, corporate governance codes, or stock exchange listing rules.
Our data divide OECD countries using four main categories:
Most countries take a soft approach to encourage representation
Sources: Deloitte; Piscopo and Muntean; The Conference Board of Canada.
(n = 36; percentage of countries)
Quotas
Soft quotas are the most-used approach internationally: limited penalties, voluntary targets, and a reliance on stakeholder or public accountability and governance practices to increase the share of women on boards. Canada uses a soft but unique approach - publicly traded companies have to disclose women's representation but are not held to a specific target or quota. Companies are also asked to specify whether a target has been adopted, and an explanation if not, but does not recommend the adoption of a specific target.
What we’re seeing
Different countries, different policies,
different results
Canada: 18% of all board seats for companies covered by disclosure are women. For the largest 60 of these companies, women hold 30% of board seats
Hard quotas: Average 31% of board members are women
Denmark
France
Greece
Iceland
Israel
Norway
Portugal
Soft quotas: Average 26% of board members are women
Australia
Chile
Finland
Ireland
Japan
Luxembourg
Netherlands
New Zealand
Slovenia
Spain
Sweden
Switzerland
Turkey
United Kingdom
Soft quotas
Hard quotas
Canada
Critical mass at 30 per cent
Research shows that when at least three board positions or 30 per cent of board seats are filled by women, the boards’ culture becomes more inclusive of women.
Belgium, Italy, Portugal, and Norway have achieved critical mass on the boards of all their largest companies—and happen to rely primarily on hard quotas.
Forty per cent of Canada’s largest companies—companies on the S&P/TSX Composite Index—have achieved critical mass. Other countries are much further behind, and there is little consistency in their legislative approaches. Less than 16 per cent of the largest companies have reached critical mass in Poland (no quota) and Greece (hard quota), and less than 10 per cent in Chile and Japan (both soft quotas).
There is still much variance in representation from country to country. Some countries have been able to reach at least 30 per cent representation with soft quotas while others have struggled. Similarly, Norway and France have achieved 30 per cent representation on all of their large boards with hard quotas, while progress has been slow for other countries with hard quotas, such as Greece and Israel.
There also seems to be little correlation between representation success and how long a quota has been in place. Greece and Israel have had initiatives for about 20 years, but Greece has only seen a gain of 3.6 per cent and Israel has only gained 7.6 per cent. In contrast, Ireland had a 17.5 per cent increase in women on boards over 15 years. All three countries had representation levels below 15 per cent when quotas were put in place.
Germany, Austria, Italy, and Belgium are the only four OECD countries to use both soft and hard quotas: while most companies are subject to a soft quota or voluntary targets, a subset are mandated by hard quotas.
Nine OECD countries have no formal quotas or legislation in place. Instead, these countries have developed policies to encourage boards to recruit women, some more formalized than others. Currently, these nine countries average 14 per cent women on boards.
Among the 14 OECD countries that use soft quotas, 26 per cent of board members, on average, are women. However, the seven countries with hard quotas showed only a little more progress, averaging about
31 per cent.
Comply or explain
A “comply or explain” approach is used by 12 OECD countries, including Canada. This approach varies from country to country, but the intent is to encourage companies to be more diverse by being held to the accountability of shareholders and the public. Organizations share information about how many women are on their boards and their efforts to increase this representation, or explain why they choose not to. While Canada does use a comply or explain approach to disclosure requirements, comply or explain applies specifically to the disclosure of information, rather than compliance with a target, as in most comply or explain countries. (For more on comply or explain, see our project landing page, All on Board: Turning Evidence Into Action for Women’s Leadership.)
In all countries using comply or explain policies except Canada, this mechanism is tied to a specific nation-wide quota—though these quotas are necessarily soft due to the nature of comply or explain (i.e., formal sanctions or penalties are not enforced for failure to meet targets).
Of the 12 countries using comply or explain policies, seven have achieved 30 per cent representation on their largest boards: Austria, Australia, Germany, Finland, Belgium, Sweden, and the Netherlands.
Belgium
Italy
Portugal
Norway
Canada
Poland
Greece
Chile
Japan
Hard quota & soft quota
Hard quota & soft quota
Hard quota
Hard quota
Disclosure & hard quota in Quebec
No formal quotas or policies
Hard quota
Soft quota
Soft quota
100
100
100
100
63.0
15.8
14.3
5.9
3.4
Share of major boards with at least 3 women
Countries using comply or explain legislation
See how progress in Canada compares with other countries
that use comply or explain:
The ongoing debate
Debate on the appropriateness and impact of soft, voluntary approaches versus hard quotas is ongoing. Supporters of soft quotas or comply or explain policies argue their approach effectively encourages gender diversity on boards while ensuring boards can still select members based on experience and skills, rather than to simply reach a target. On the other side, supporters of hard quotas argue that voluntary approaches provide “loopholes” for companies that disagree with mandated quotas.
This debate is also present within jurisdictions. Our closest peer country, the United States, has no national legislation for women on boards, but a growing number of states are using legislative action. California adopted a hard quota in 2018.Hard quotas are under consideration in Hawaii, Michigan, Massachusetts, New Jersey and Washington State while mandatory disclosure requirements have been enacted in Maryland, Illinois, and New York.
For detailed information on each country’s approach and progress, check out our interactive data table here
Bringing things back to Canada
The progress made with different legislative approaches is mixed and dependent on context—governance principles, social, cultural, and political contexts. Legislation effective in one region won’t necessarily have the same outcomes in all regions. There is also
a lack of rigorous country-specific research linking different approaches directly to progress.
What does this mean for Canada? Despite the challenges in comparison, we can still see what’s worked in peer countries and consider their potential in Canada.
More importantly, these data highlight the need for a Canadian-specific analysis of our own approach and progress. Canadian decision-makers need to know how well comply or explain policies are working—at home and abroad—so they can ensure the best approaches to increase representation are in place.
At The Conference Board of Canada, we are addressing this challenge by evaluating whether and how women are more represented on boards and the organizational practices and characteristics that matter most for this progress.
To learn more, check out our project page here
Click here to view our sources
Maria Giammarco
Nimi Pukulakatt
Senior Research Associate
Research Associate
Back to top
Get a deeper look into the debates around these approaches by reading our impact paper, All on Board: Turning Evidence Into Action for Women’s Leadership.
Sources: Emelianova and Milhomem; The Conference Board
of Canada
Note that country averages are impacted by the number of companies and size of companies included in each country’s reported results. For example, Australia and the UK report on their top companies and their average is thus inflated, whereas Canada’s average reflects all disclosure companies. When limited to the top companies (i.e., TSX60) representation reaches 30%.
Sources: Deloitte; Piscopo and Muntean; The Conference Board of Canada.
(percentage)
Comparisons around
the world for women's leadership
Comparisons around
the world for women's leadership