CEO pay ratio: how to find a public company's median employee pay

If you want to know what a typical worker earns at a big public company, the company has already told you. US-listed companies (other than the exempt types covered below) must publish their median employee's annual pay every year, right next to the CEO's. Apple's 2026 proxy statement, for example, puts its median employee's fiscal 2025 total compensation at $139,483, while Costco's proxy covering fiscal 2025 reports $49,186. This guide shows you how to find that number for any company, what it really measures, and how to use it without being misled.

Quick reference

A quick word on "median": line up every employee from lowest to highest paid, and the median is the person in the middle. Half earn more, half earn less. Unlike an average, a few very highly paid people do not drag it up.

What the SEC pay ratio rule requires

The SEC adopted the pay ratio rule in 2015 (effective October 19, 2015), and companies had to comply starting with their first fiscal year beginning on or after January 1, 2017. The rule sits in paragraph (u) of Item 402 of Regulation S-K, the SEC's executive pay disclosure rule. It requires three numbers:

• The median of the annual total compensation of all employees, leaving out the CEO
• The CEO's annual total compensation
• The ratio between the two, shown either as the CEO's pay compared with 1, or described in words as a multiple

"Total compensation" is calculated the same way as for executives in the Summary Compensation Table: salary, bonus, stock and option awards, non-equity incentive pay, certain pension and deferred pay gains, and all other compensation. For hourly workers, the rule lets companies read "salary" as wages plus overtime.

"Employee" covers full-time, part-time, seasonal and temporary workers employed by the company or its consolidated subsidiaries on a date the company picks within the final three months of its fiscal year. Independent contractors and "leased" workers whose pay is set by an outside firm are not counted.

Which companies are covered? The final rule says the disclosure does not apply to emerging growth companies, smaller reporting companies or foreign private issuers. So a recently listed startup, a small-cap firm or a foreign company filing its own home-country reports may have no pay ratio at all.

Finding a company's proxy statement on EDGAR

EDGAR is the SEC's free filing database. Its full-text search covers electronic filings back to 2001. Here is the quickest route:

1. Go to EDGAR Full Text Search.
2. Type the company name or ticker in the company field and pick it from the drop-down list.
3. Click "more search options," then use the filing types menu to select DEF 14A (the definitive proxy statement).
4. Sort or scan by filing date and open the most recent one. Most companies file their proxy once a year, a few weeks before the annual shareholder meeting.
5. Click the form link in the results to open the document.

If the company has no DEF 14A, try its 10-K. The rule allows the pay ratio to go in the annual report, and some companies put executive pay there or add it later in an amended 10-K.

Want to scan many companies at once? Search the exact phrase "pay ratio" in quotation marks, filter to DEF 14A and a date range. The EDGAR search FAQ explains the exact-phrase, exclusion and NEAR operators if you want to narrow results, for example "median employee" NEAR(10) "retail".

Many companies also post the same proxy as a PDF on their investor relations site. That version is still the company's own filing, and it is often easier to search.

Locating the pay ratio section

Proxy statements are long. Do not read front to back. Use your browser's find tool (Ctrl+F or Cmd+F) and try these terms in order:

• "pay ratio"
• "median employee"
• "median compensated employee"
• "ratio of"

The section is usually short, a page or less, and sits near the end of the executive compensation tables, often just before or after "Pay Versus Performance." In Apple's 2026 proxy the heading is "CEO Pay Ratio" followed by the year; in Costco's it is "CEO PAY RATIO."

When you find it, write down five things:

• The fiscal year the figure covers (not the year the proxy was filed)
• The median employee's total compensation
• The compensation measure used to pick the median employee (base pay only, or pay including bonuses and equity)
• Who was excluded, such as non-US employees in certain countries or staff from a recent acquisition
• Any supplemental ratio the company added, for example one that covers only full-time staff

Those notes matter more than the headline figure, as the next sections show.

How companies identify the median employee

The rule gives companies real flexibility in how they find the person in the middle. Here are the main choices, all drawn from the rule's text and instructions.

The date. The company picks a date within the final three months of its fiscal year to define its workforce, and must disclose that date. Apple used September 27, 2025, the last day of its fiscal year.

The measure. A company does not have to calculate full total compensation for every worker just to find the median. It can use any compensation measure it applies consistently to everyone, such as payroll or tax records, and must say which measure it used. Apple used base salary, bonuses, commissions and the grant date value of equity awards. Costco used a mix of salary, bonus, equity and other measurable benefits.

Sampling and estimates. Companies may use statistical sampling or other reasonable methods, and reasonable estimates, as long as they describe the method briefly and flag the estimates.

Every three years. A company only has to re-identify its median employee once every three years, unless its workforce or pay arrangements changed enough to significantly affect the ratio. In between, it recalculates that same employee's pay each year. Apple said it identified a new median employee for 2025.

Part-time and temporary staff. Part-time, seasonal and temporary workers count. Companies may annualize pay for permanent employees, full-time or part-time, who joined partway through the year or were on unpaid leave. They may not annualize pay for temporary or seasonal workers, and they may not convert a part-timer's pay to a full-time equivalent. That last point is why retailers and restaurants with many part-timers often report low medians.

International workers. Non-US employees generally count, but there are two exemptions:

• A data privacy exemption, where a country's privacy laws prevent the company from collecting the data. The company must name the country and law and file a legal opinion.
• A "de minimis" exemption: a company whose non-US staff make up 5% or less of its total workforce can drop all of them. A company above that threshold can exclude non-US employees adding up to no more than 5% of its total workforce, but it must exclude whole countries, and it cannot exclude a country that alone holds more than 5% of its employees.

Costco used the de minimis exemption. Its proxy says it had approximately 336,700 employees worldwide, about 222,000 of them in the US and its territories, and that it excluded employees in seven countries (Spain, France, Iceland, Sweden, China, New Zealand and Taiwan), leaving a considered population of about 323,800.

Cost-of-living adjustments. A company may adjust overseas employees' pay to the cost of living where the CEO lives. If it does, it must also show the unadjusted figure.

Acquisitions. Employees who joined through an acquisition can be left out for the fiscal year the deal closes, as long as the company says roughly how many it omitted.

Why median pay varies so much between companies

Put two medians side by side and the gap can look enormous. Here are the two examples from this guide, each quoted from the company's own filing.

Several things drive differences like these:

• Workforce mix. A company built around engineers and corporate staff will report a higher median than one built around store, warehouse or restaurant jobs. The median reflects who the company employs, not how generously it pays any one role.
• Part-time share. Costco says about 37% of its considered population were part-time, seasonal or temporary. When it reran the calculation with only full-time workers, the median rose from $49,186 to $66,262. Same company, same year, very different number.
• Equity. Stock awards count at their grant date value. At a company that grants stock widely, the median can include a sizable equity slice that a cash-only employer will not show.
• Geography. Large non-US workforces in lower-wage countries pull the median down, unless they are excluded or cost-of-living adjusted.
• Method. Each company chooses its own date, measure, exclusions and estimates. Both Apple and Costco say directly that their ratio may not be comparable with other companies' ratios.

So treat cross-company comparisons with care. A higher median does not tell you a company pays more for the same work. It may just employ a different mix of people.

What the median figure includes, and what it leaves out

The pay ratio median is total compensation, not base pay. That means it can bundle together:

• Base salary, or wages plus overtime for hourly staff
• Bonuses, commissions and incentive pay
• Stock awards and options at grant date value, which may vest over several years
• Other compensation, such as company retirement contributions

Companies may also choose to include personal benefits worth less than $10,000 and pay under broad-based benefit plans like health coverage, but only if they add the same items to the CEO's figure. Check the methodology note to see which way a company went.

The CEO side is dominated by equity in many filings. Apple's Summary Compensation Table shows its CEO's fiscal 2025 total of $74,294,811 was made up of $3,000,000 in salary, $57,535,293 in stock awards, $12,000,000 in non-equity incentive pay and $1,759,518 in other compensation.

What the median does not include: shift differentials paid by a contractor, the pay of leased or agency workers, and anything about the value of benefits the company chose not to count. Data on those is not published in the pay ratio section.

Other pay information in the proxy

While you have the proxy open, these sections are worth a look:

• Compensation Discussion and Analysis (CD&A). The company explains what its executive pay program rewards, each pay element, and how it sets amounts. It often names the peer companies it benchmarks against, which doubles as a list of employers competing for similar talent.
• Summary Compensation Table. Salary, bonus, stock awards, incentive pay and other compensation for the CEO, CFO and other top executives, usually for the last three fiscal years.
• Pay Versus Performance. Required by Item 402(v), it compares "compensation actually paid" to executives with company results.
• Say-on-pay proposal. Shareholders cast an advisory vote on executive pay.
• Director compensation. What board members are paid.

None of these give you pay for non-executive roles. The pay ratio is the only place in the proxy where the company reports a figure for its rank-and-file workforce.

Using the figure alongside job-level data

The median employee figure is one person's total compensation at one company. It is not a measure of what any specific job pays there. To judge an offer or a raise, pair it with role-level data.

The Bureau of Labor Statistics' Occupational Employment and Wage Statistics (OEWS) survey is the standard free source. Its May 2025 overview tables list these annual mean wages (a mean is the ordinary average):

Hypothetical example: you are weighing a full-time stocking job at a big warehouse retailer whose proxy reads like Costco's, with an all-employee median of $49,186 and a full-time-only median of $66,262. The BLS national mean for stockers and order fillers is $39,540. Together these suggest the company's full-time workforce as a whole is paid well above the national average for that occupation, but neither tells you what your role pays. The full-time median blends every full-time job, from entry-level roles to managers. For your number you still need the posted range, the offer letter, or role-level data for your metro area.

A practical routine:

1. Pull the company's pay ratio median and note the year, measure and exclusions.
2. Look up your occupation's national and metro pay in OEWS, including the percentile spread.
3. Check the job posting's pay range, which many states and cities now require.
4. Compare your offer with all three, and treat the company median as context, not a target.

Find more role-level figures on our salaries by role pages and employer breakdowns on company pay.

Using the pay ratio in a pay conversation

The pay ratio rarely wins a negotiation by itself, and leading with the CEO's pay can put a hiring manager on the defensive. It works better as quiet evidence that the company can afford market pay, or that your role sits above the company median.

Here are short scripts you can adapt:

• At offer stage: "I looked at the company's latest proxy. Its median employee total compensation was around [figure] for [fiscal year]. Given that this role needs [skill], I was expecting a base closer to [your number]. Is there room to get there?"
• When the company's median includes equity: "The proxy's median figure includes stock awards. Can you walk me through what equity this role is eligible for and how it vests?"
• At review time: "Our full-time median in the proxy rose to [figure]. My pay has not moved in [period]. I'd like to talk about bringing it in line with [market data source]."

Keep the focus on your role, your results and market data. For more scripts, see our negotiation guides, and for wider wage and disclosure changes, track pay trends.

What to do next

• Pick one employer you care about and find its latest DEF 14A on EDGAR today.
• Note the median, the fiscal year, the compensation measure and any exclusions or supplemental ratios.
• Pull role-level data for your job and city before you draw conclusions.
• If the company is exempt or has no proxy, rely on posted pay ranges and public wage data instead.
• If you have questions about how a specific company calculated its figure, its investor relations team is the place to ask.