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CEO Pay Ratio Disclosure, Explained

Since 2018, every public company must publish one number: CEO compensation divided by the median employee's — a metric designed for shame that turns out to be hard to compare.

LF
Lena Fischer, · March 4, 2026 · 3 min read
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Executive pocket watch beside an hourly employee's timecard punch card

The CEO pay ratio — total chief-executive compensation divided by the median employee's, as computed under a Securities and Exchange Commission rule that took effect for fiscal 2017 filings — forces every U.S. public company to print one number framing executive pay against its own workforce. The S&P 500 median has run in the 180-to-250 range in recent years, meaning the typical large-company CEO earns roughly two hundred times the median employee, per Equilar's annual tracker. But the same rule that produces the number also limits what it can be used for: methodology choices swing the ratio by multiples, and neither the numerator nor the denominator means quite what intuition suggests.

The Daily News 24 publishes information, not investment or policy advice. This explainer covers a disclosure rule.

How is the ratio computed?

CEO pay in the numerator follows the Summary Compensation Table: salary, bonus, the grant-date accounting value of equity awards, and change in pension value — accounting constructs, not cash received. The denominator identifies the median employee using annual total compensation with three permitted simplifications: companies may use statistical sampling instead of a full census, may exclude non-U.S. employees up to 5 percent of the workforce, and may annualize pay for full-time equivalents who worked only part of the year. Each choice moves the median, and the SEC requires no standardization among them.

Why do ratios vary so much across similar companies?

Because the denominator is an employment model, not an economic constant. A retailer with hundreds of thousands of part-time clerks computes a median near entry wages; a software firm with a homogeneous salaried workforce computes a median many times higher — so the retailer's ratio looks enormous while its CEO may earn less in absolute terms. Global staffing mixes, the 5 percent foreign exclusion, and sampling choices add further spread. Comparisons over time within one company are cleaner than comparisons across companies, and even within a company a change in outsourcing or part-time mix resets the median.

What does the equity component do to the number?

Stock and option grants, valued at grant date under accounting rules, typically form 60–80 percent of large-company CEO pay. That makes the ratio swing with share-price volatility and grant timing rather than with cash decisions: a single large multi-year retention grant can double a ratio in its grant year and fade after. Boards counter that realized pay — what executives actually keep — diverges from granted pay when stock prices fall, which is true and also visible only in the multi-year supplemental tables, not the headline ratio.

Where did the rule come from?

The 2010 Dodd-Frank Act directed the SEC to adopt it; the implementing rule arrived in 2015, with first disclosures in 2018 proxy statements after legal challenges. Its purpose was transparency and political, in the plain sense: a single comparable-sounding figure for campaigns and press coverage. Institutional shareholders largely ignore it in voting analyses — proxy advisers focus on pay-for-performance alignment — while it reliably anchors news coverage each spring proxy season.

How should readers use it?

Read the ratio beside three footnotes: the methodology section describing sampling and exclusions, the workforce description (employee count, part-time share, geography), and the equity-award assumptions. A 250:1 at a hamburger chain and a 40:1 at a consultancy are facts about their workforces as much as their CEOs. The number earns its place on the page; it just does not travel well between pages.

Frequently Asked Questions

What is the CEO pay ratio?
A required SEC disclosure since fiscal 2017 filings: total CEO compensation divided by the median employee's total compensation. The S&P 500 median has recently run about 180 to 250 times.
Why is the CEO pay ratio hard to compare across companies?
The median employee reflects each firm's workforce mix — part-time clerks versus salaried engineers — plus permitted methodology choices like sampling, foreign exclusions, and annualizing that each move the number.
Does the CEO pay ratio measure cash pay?
No — it uses grant-date accounting values of equity awards, typically 60–80 percent of large-company CEO pay, so ratios swing with grant timing and share volatility rather than cash decisions.
What law created the pay ratio disclosure?
Section 953(b) of the Dodd-Frank Act of 2010 directed the SEC to adopt it; the rule was finalized in 2015 with first disclosures in 2018 proxies.