Pay Equity Starts with Transparency

Gender Pay Gap Reporting

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The What and the Why


of Gender Pay Gap Reporting

The EU Pay Transparency Directive requires all companies with more than 100 employees, or less depending on local legislation, to publish information about their gender pay gap.


The report should be published on your company website or some other publicly available channel and must also be shared with national authorities and workers' organizations.


The pay levels should include all variable pay components and be expressed as gross annual pay, and the corresponding hourly pay, thus allowing comparison between employees regardless of their work circumstances.

The background for the EU Pay Transparency Directive is an experience that despite previous legislation around equality, the lack of pay transparency leads to (unintentional) gender discrimination going undetected, and it also makes it hard to prove in situations where discrimination does occur.


It is important to note that pay equity does not preclude employers from differentiating pay based on objective, gender-neutral criteria like performance and competence; it simply gives everyone a fair chance at equal pay for equal work.

If your report concludes a Gender Pay Gap that exceeds 5% and which cannot be justified by gender neutral factors, you are facing and Pay Equity Gap and must carry out a pay assessment in collaboration with workers’ representatives and adjust your pay structure to eliminate the issues.


Worst case you may need to compensate employees who have suffered gender pay discrimination, potentially going back to their time of employment. The directive also asks member states to penalize companies who fail to be fair.


Hence, working on reducing existing pay gaps before the legislation enters into force could be a significant advantage.

What's the difference between a Gender Pay Gap and an Equal Pay Gap?


The Gender Pay Gap is the difference in total remuneration between men and women in the same Category of Workers. 


There are many factors at play and a pay gap in itself is not an issue if it can be explained by objective, gender-neutral factors - this is what is known as the "explained gender pay gap".


If a portion of the pay gap cannot be objectively justified, you are dealing with a so-called "unexplained gender pay gap" - which in technical terms is referred to as the Equal Pay Gap.


If your Gender Pay Gap exceeds 5%, and the joint assessment identifies an Equal Pay Gap your company will need to take measures to eliminate the gap. 

The Who


of Gender Pay Gap Reporting


The main purpose of the EU Pay Transparency directive is to raise awareness among employers about the principle of equal pay. This principle has been at play for many years in EU legislation but despite this the Gender Pay Gap has not changed much over the past decade. With this new demand for gender pay reporting, European employers are thus being nudged to evaluate and monitor pay structures and policies systematically to ensure fairness in remuneration and eliminate pay discrimination.


It also raises awareness and among the employees and empowers them to act against gender-bias and discrimination in remuneration and provides authorities and other stakeholders with relevant information about the gender pay gap in your company, in the community and on a European level. The public reporting aspect also allows for monitoring and comparison across sectors.


As a company, you are entitled to provide explanations of any identified gender pay differences in your report, and if gender pay gaps cannot be explained by gender-neutral objective criteria you must take measures to rectify the problem.


When looking at the deadlines below, please note that the directive allows member states to implement their local legislation at a quicker pace and also make regular reporting mandatory for companies with fewer than 100 employees if they find it locally relevant.

Important deadlines to keep in mind


June 7, 2026


European member states must be finished transposing the directive into local legislation.

June 7, 2027 


Companies with 250+ employees must publish their first annual gender pay gap report.


Companies with 150 to 249 employees must publish their first gender pay gap report and do this every three years thereafter.


Member states may choose to make the requirements applicable to companies with fewer employees too.

June 7, 2031 


Companies with 100 to 149 employees must publish their first gender pay gap report and do this every three years thereafter.

Reporting Leads to Transparency


Transparency Leads to Fairness


With the Pay Transparency Directive, the European companies are now encouraged through legislation to review their pay structures and be transparent about their findings. Transparency actuates pay fairness for women and men working in same jobs or jobs of equal value and it empowers potential victims of discrimination to exercise their rights.


The required reporting on gender pay comprises total remuneration and not just the base salary component. In the publication of the directive by the Official Journal of the European Union they list a number of examples of variable pay components that should be included in the total remuneration analysis: bonuses, overtime compensation, travel facilities, housing and food allowances, compensation for attending training, payments in the case of dismissal, statutory sick pay, statutory required compensation and occupational pensions. They emphasize that this is not a complete list; your company could be working with additional pay components that you will need to take into account. 


What Happens if an Equal Pay Gap is Found?


If your Gender Pay Gap report concludes a pay gap of at least 5% between men and women in any given Category of Workers, you must review your findings with the workers' representatives. If together you conclude that the pay gap can be explained by gender-neutral, objective criteria all is well.


However, if it turns out that you have an Equity Pay Gap of 5% or more you need to carry out a joint pay assessment unless you can effectively remedy the difference in pay level within 6 months from the publication of the report.


Learn more about the requirements of the Pay Gap Report here.


What is a Joint Pay Assessment?


A Joint Pay Assessment is an evaluation of your company's gender pay gap that is carried out by the employer together with the workers' representatives. If your company does not have designated workers' representatives your employees should dedicate someone for this purpose. 


The Joint Pay Assessment should result in a revision of the company's pay structures thus eliminating gender-based pay discrimination within a reasonable period of time, yet to be specifically defined in local legislation. 


Learn more about the Joint Pay Assessment here.


How to remedy an Equal Pay Gap


First, you run a Gender Pay Gap analysis, or you can book an Equal Pay Audit through us. Once you have an overview of your current pay landscape, you begin to create a plan for addressing any issues that have been uncovered. This can be done in many ways; some things are easily fixed during your ordinary salary review process while other things may need an out of cycle review or can only be addressed in stages. 


Learn more about Fixing an Equal Pay Gap here.


Required Content of
the Gender Pay Report


Please keep in mind that the EU Pay Transparency Directive still needs to be transposed into local legislation and thus might differ slightly from country to country. However, ceteris paribus, this is what the directive says about the reporting requirements in terms of content.


The reporting requirement concerns companies with more than 100 employees; however, this could be less depending on the local legislation.The information in the report will be used by the authorities to publish country wide reports on gender pay, which in turn are used by Eurostat to monitor the development of the gender pay gap across all member states.


As an employer, you can publish your report on your website, in your annual report or some other publicly available channel and there will likely be additional local requirements about how to report to the authorities. The report must be made available to all employees and workers' representatives.


The Directive asks that the report contains the following information:

  • the gender pay gap;
  • the gender pay gap in complementary or variable components;
  • the median gender pay gap;
  • the median gender pay gap in complementary or variable components;
  • the proportion of female and male workers receiving complementary or variable components;
  • the proportion of female and male workers in each quartile pay band;
  • the gender pay gap between workers by categories of workers broken down by ordinary basic wage or salary and complementary or variable components;
  • if available, the information from the previous four years.


    The EU Pay Transparency Directive also stipulates that employees, workers' representatives and the authorities can ask the company for additional details and clarifications regarding the data, including explanations concerning any gender pay gaps. As a company you will need to be able to respond to such inquiries within "reasonable time", which is yet to be defined. If any gender pay gaps turn out to be equal pay gaps you will need to fix the issues in 6 month in collaboration with workers' representatives and the authorities. 


    Experiences from Sweden and Iceland, where similar legislation was already implemented, shows that for most companies the reporting requirement sets high demands on their job structure and systems in order to ensure compliance. Building your job hierarchy with title structures and salary bands requires Rewards expertise and extensive experience to ensure against the costly pitfalls of the project. Thus, we highly recommend getting help, if you do not yet have a job structure in place. Once your job structure is in place, there are many advantages to subscribing to an equity software that allows you to run real-time reporting, comparisons and enables better ongoing monitoring of your equal pay landscape.

    Requirements of the
    Joint Pay Assessment


    The EU Pay Transparency Directive tasks companies with Gender Pay Reporting and eliminating Equal Pay Gaps.


    In order to ensure that remedial actions take place if an Equal Pay Gap is identified, the directive stipulates a so-called Joint Pay Assessment in cases where your gender pay reporting:


    1. reveals a Gender Pay Gap of at least 5% in any Category of Workers,
    2. you cannot justify the gap using objective, gender-neutral criteria,
    3. and you have not remedied the Equal Pay Gap within 6 months of the date of your pay report.  


    The purpose of the Joint Pay Assessment is to fix the problem and prevent it from reoccurring.


    This deep-dive into the salary data must include:

    • an analysis of the proportion of female and male workers in each category of workers;
    • information on average female and male workers’ pay levels and complementary or variable components for each category of workers;
    • any differences in average pay levels between female and male workers in each category of workers;
    • the reasons for such differences in average pay levels, on the basis of objective, gender-neutral criteria, if any, as established jointly by the workers’ representatives and the employer;
    • the proportion of female and male workers who benefited from any improvement in pay following their return from maternity or paternity leave, parental leave or careers’ leave, if such improvement occurred in the relevant category of workers during the period in which the leave was taken;
    • measures to address differences in pay if they are not justified on the basis of objective, gender-neutral criteria;
    • an evaluation of the effectiveness of measures from previous joint pay assessments.


    You are obliged to share this elaborate report with your employees and workers' representative, as well as the authorities. 


    The Joint Pay Assessment should lead to specific measures that can ensure fairness, and these must be implementet "within a reasonable time period" in cooperation with the workers' representative as pertaining to local legislation. The authorities can be included in this process.


    The measures taken must include an analysis of your existing gender-neutral job evaluation and classification systems - a.k.a. your job structure or job architecture - or the establishment of such if you do not have those in place already. This is to ensure against any unfair pay discrimination.


    Hence, it would be wise to be prepared before the requirements enter into force in your country. 

    2

    Adding

    Relevant Data

    Step 2


    Add additional salary determinants, such as age, education, experience, management responsibilities, etc., and make sure they have a legitimate relation to pay. You also want to include variable pay elements and applied benefits.

    3

    Run a

    Pay Gap Analysis

    Step 3


    Run a Pay Gap Analysis by applying statistical modelling, building on regression analysis that estimates the causal relationship of differences in pay.

    This measures the impact of each variable and quantifies pay gaps.

    4

    Refine

    your Analysis

    Step 4


    Review all employees who are paid significantly less (or more) than the regression model predicts, thus identifying other factors that should be included in your model. Keep refining until the model includes all relevant variables.

    1

    Data

    Structure

    Step 1


    Structuring existing data by grouping employees into relevant categories using gender neutral criteria. It is important to ensure that the positions compared are of equal importance to the organization

    Four Steps to Pay Transparency

    Knowing the Equal Pay Gap exists is the very first step toward rectification; hence you begin by running an equal pay analysis either in a spreadsheet or in an equal pay software.


    To run the equal pay analysis, you need to have a job structure (also known as a job architecture or a job classification system) in place to ensure that the positions compared are of equal value to your organization.


    Depending on the size and complexity of your organization you can either create the job classification system yourself, bring in an interim expert to build it or use AI-powered solutions. If you choose the latter, we recommend that you conduct a manual sanity check, as the AIs still make too many mistakes to blindly depend on their classification. The purpose is to fix unfairness and you don't want to run the risk of creating new or different discriminating pay gaps in the process.


    Once you have run the Pay Gap Analysis and refined your model, so it matches your company's compensation strategy, you have the necessary overview of your current pay landscape. Then it is time to review the cases that shows an Equal Pay Gap and plan for their elimination - the equal pay gaps that is; not the people ;)


    You can find inspiration for this process here.


    It is important to look at this from all perspectives, as the solution is (at least) two-fold: Addressing existing unfairness and ensuring against new equal pay gaps. The latter is done through a review of your policies, especially around parental leave and part time employees, to make sure all employees, regardless of their work circumstances, have access to promotions and are included in the salary review cycle.


    Transparency is a Precondition for Workplace Equity

     

    Workplace equity is a principle many companies are already aiming to achieve regardless of the new pay transparency legislation. This is because workplace equity is the more feasible direction in the long run. Being a fair employer is good for your employee satisfaction and retention rates, as fairness motives and creates trust. Many studies have shown that a diverse workforce leads to higher creativity and more opportunities; it ensures a better work environment, higher productivity and is thus good for the bottom line. In short, you could say that: 


    Pay Equity isn't just the right thing to do - it's good business too


    Transparency is the main driver of equity. With pay transparency you empower your current and future employees to take responsibility for their own career growth, as the different paths and goals become clear.


    Seen in the long perspective, pay equity is not even an added cost for your company. Here and now it may require adjustments in the remuneration of some individuals, but without such adjustments, chances are those individuals would have left your organization for greener and more fair pastures, which would incur additional recruitment and training costs, as well as loss of valuable knowledge. 


    One of the requirements of the EU Pay Transparency Directive is to publish an equal pay report. In this report you will naturally want to go one step deeper to explain the salary differences by role to highlight the actual differences between gender. With the legislation comes a requirement that if your company's Gender Pay Gap exceeds 5% and cannot be justified by gender neutral factors, you have to carry out a pay assessment in collaboration with workers’ representatives and worst case you may need to compensate employees who have suffered gender pay discrimination going back to their time of employment. Depending on local legislation you might also get fined or face other measures. 


    The purpose is to look at jobs that are “like for like” and this will be an essential part of the analysis. However, comparing equal job or jobs of equal value requires a strong job architecture, which takes time to build and refine. In that perspective three years is not a long time; hence, we recommend that you start planning for the implementation of the report as soon as possible. 

     
     
     
     
     

    A Prerequisite for Gender Pay Reporting


    Job Architecture


    The Job Architecture provides a solid foundation to work with pay transparency and pay equity. It is a structure that facilitates compliance with most of the requirements in the Pay Transparency Directive, as it enables cross-function comparison by level, salary bands and clear and communicable career paths.


    When creating the Job Architecture, you start by dividing your employees into Categories of Workers by function and level and settling on the appropriate salary bands as per your remuneration strategy. 


    Then you describe each position using objective criteria. The minimum requirement set forth by the European Union are skills, effort, responsibility and working conditions. However, you may also want to include elements such as educational background and professional and training requirements. All these factors are not equally relevant for a specific position and should thus be weighted depending on their relevance.


    When a company under the Pay Transparency legislation requirements have positions that do not correspond to any internal comparables within your organization, the Pay Transparency Directive says to use a hypothetical comparator, thus enabling your employees to evaluate their individual pay. However, working with a Job Architecture that employs a levelling structure allows you to compare any employee across your organization, even when they are the solo person in a specific function, as they can be compared to colleagues in different jobs that have equal value to the organization.


    Each function in your organization is evaluated on its relative contribution criteria, which provides you with an objective and gender-neutral way to show your employees how they compare and also enables you to provide a hypothetical comparator, if needed, based on levels.


    Working with a Job Architecture that includes salary spans gives you a vital overview of your pay landscape in real-time and facilitates comparison of salaries across functions with truly similar positions. The added bonus is that the Job Architecture also enables your Hiring Managers to define the role more precisely, including responsibilities and expectations, and include a pay range in the job ad.


    As the Job Architecture enables comparison of jobs of equal value across the entire organization, across functions and job families, based on objective, gender-neutral criteria, it also eliminates the risk of Equal Pay Gaps and provides a warning flag if (unintended) discrimination occurs at any level.


    In other words, the Job Architecture enables the much sought-after transparency and can be instrumental in ensuring against Equal Pay Gaps and unfairness in remuneration.

    Pay Structure


    A pay structure is a valuable tool for your managers, as it helps them in their annual salary review dialogue with your employees.


    The salary span for a given position is defined thorough the structure and each individual salary lies somewhere within this span depending on how the employee relates to the relevant criteria. 

    Definition of Pay Structure
    Definition of Basic Job Architecture

    A Basic Job Architecture


    The most simple version of the job architecture provides a structure in which the various functions are grouped into Categories of Workers and divided by career streams. Functions are defined by the value they provide the company.


    A salary span is defined for each function, thus allowing comparison across various Categories of Workers.

    The Expanded Job Architecture


    The most common Job Architecture is a bit more nuanced than the basic version above. By working with levels and job families, you can define your salary spans more precisely and thus your promotion criteria and career paths.


    For each level you make a gender-neutral, objective description of what is required of an individual in said level, which again is a valuable tool for your managers in their ongoing employee dialogues.

    Definition of Expanded Job Architecture
    Definition of Job Architecture and Pay Structure

    Job Architecture with Pay Structure


    In this example the Job Architecture relates to the Pay Structure, showing the salary spans for each level, as well as the individuals currently within that span. It also compares your salary spans with the current market value for each level.


    Using job families allows a more nuanced structure, in which career paths can also move sideways, as not every employee dream of becoming a manager.