EU Pay Gap Report (Pay Transparency Directive)

About the EU Pay Gap Report (Pay Transparency Directive)

The EU Pay Transparency Directive (Directive (EU) 2023/970) makes employers with 100 or more workers report on the pay gap between women and men. Article 9 lists what they report: the gender pay gap, the gap in complementary or variable pay, the median gaps, the share of women and men receiving variable pay, the share of each in every quartile pay band, and the gap by category of workers doing the same work or work of equal value, split into basic and variable pay. Where a category shows a difference of at least 5 % that the employer has not justified on objective, gender-neutral criteria, Article 10 calls for a joint pay assessment with the workers’ representatives.

Choose your payroll export — one row per worker with their sex, category, basic pay, each complementary or variable component and the hours paid — and the report works out every indicator on annual and on hourly pay, the quartile bands, the categories with the 5 % test, the reporting cycle for your headcount and the data checks that matter (workers recorded as neither female nor male, missing pay, repeated ids, categories too small to compare). Type the justification for any category that needs one.

The payroll is read on this device and never uploaded. The free preview runs on your own file and shows the counts, the categories and the data checks with the gap figures hidden; the XLSX workings and the PDF report need a Premium pass.

Common uses

• HR and reward teams preparing the first pay reports under the Directive.
• Employers with 100 to 249 workers checking where they stand before their reporting date.
• Finding the categories of workers where a joint pay assessment may be needed.
• Consultants and auditors checking an employer’s figures from its payroll export.

What Article 9 asks for

Article 9(1) of the Directive lists the information employers provide:

• (a) the gender pay gap;
• (b) the gender pay gap in complementary or variable components;
• (c) the median gender pay gap;
• (d) the median gender pay gap in complementary or variable components;
• (e) the proportion of female and male workers receiving complementary or variable components;
• (f) the proportion of female and male workers in each quartile pay band;
• (g) the gender pay gap between workers by categories of workers broken down by ordinary basic wage or salary and complementary or variable components.

Items (a) to (g) go to the national authority that compiles and publishes them, and the employer may publish (a) to (f) on its website (Article 9(7)). Item (g) goes to all workers and their representatives, and to the labour inspectorate and the equality body on request (Article 9(9)). The employer’s management confirms the accuracy of the information after consulting the workers’ representatives (Article 9(6)).

When reports are due

• 250 or more workers: by 7 June 2027 and every year after.
• 150 to 249 workers: by 7 June 2027 and every three years after.
• 100 to 149 workers: by 7 June 2031 and every three years after.
• Fewer than 100: not required by the Directive; you may report voluntarily, and national law may require it (Article 9(5)).

Each report covers the previous calendar year. The page works out your next date from the headcount — the rows of your file, or the number of workers you type when the file is not the whole workforce.

How the figures are worked out

• Pay is the ordinary basic or minimum wage or salary plus any other consideration in cash or in kind — the complementary or variable components such as bonuses, overtime, allowances and benefits in kind (Article 3(1)(a)). Enter the gross amounts paid for the calendar year.
• Pay level is the gross annual pay and the corresponding gross hourly pay (Article 3(1)(b)): the hourly figure divides the year’s pay by the hours paid, so part-time work is compared fairly.
• Gender pay gap = (men’s average pay level − women’s) ÷ men’s average × 100; the median gap uses the median instead of the average (Article 3(1)(c), (e)).
• Quartile pay bands rank the workers by pay level into four groups as equal as possible (Article 3(1)(f)). Where workers with the same pay straddle the line between two bands, the women and men among them are shared out between the bands in proportion, so the order of the rows in the file never decides it.
• Variable pay gaps compare the workers who receive variable pay (or, if you choose, all workers); item (e) gives the share of women and of men who receive any.
• Workers recorded as neither female nor male are counted in the headcount but not in the gaps, which the Directive defines between female and male workers.
• Figures are shown to one decimal place; a category is flagged when its gap, so rounded, is 5.0 % or more in either direction.

Categories of workers and the joint pay assessment

A category of workers groups workers doing the same work or work of equal value, in a non-arbitrary way, by objective, gender-neutral criteria — skills, effort, responsibility and working conditions (Articles 3(1)(h) and 4(4)). The categories come from your own job evaluation: give each worker theirs in the file.

Under Article 10(1), employers that report must carry out a joint pay assessment with the workers’ representatives where all three hold: the reporting shows a difference in average pay level of at least 5 % in a category; the employer has not justified it on objective, gender-neutral criteria; and it has not been remedied within six months of submitting the report. The assessment then analyses the categories, the reasons for the differences and the measures to address them (Article 10(2)).

National laws

The Directive sets the minimum; each member state’s law transposing it may add rules — who counts as a worker for the threshold, the reporting body, the format and the dates. Check your country’s law and guidance, and keep the workings: the XLSX file lists every worker’s pay level, the band they fall in and each row left out, with the reason.

Limitations

• Not legal advice, and not a national reporting format: national laws may set their own rules, format and dates.
• The categories of workers must come from your own gender-neutral job evaluation; the tool does not create them.
• It works out the figures; it does not submit them to the national authority.
• Amounts must be the gross pay for the calendar year (monthly amounts can be multiplied by 12, which is right only for workers who were paid for the whole year).
• Up to 200,000 rows; the first sheet of a workbook is read. Justifications you type stay on this page until you reload it, and go into the exports.

Privacy

The payroll file is read in your browser and never uploaded or stored. Only your choices (amounts, decimal mark, pay basis, organisation name and currency) are remembered in this browser for next time.