1. Governance, Roles & Responsibilities (Accountability)
Appoint a compliance owner (e.g., HR/Comp & Ben lead)
Form a cross-functional compliance team (HR, Legal, Payroll, IT)
Maintain a compliance file (policies, pay data, job evaluation methodology, communication records)
Define an escalation process for disputes or complaints
2. Job Evaluation & Pay Structures (Structure)
Review job evaluation methodology and classification system to ensure clarity and gender-neutrality
Document pay-setting criteria (skills, responsibility, effort, working conditions)
Audit existing pay structures to identify risks of systemic bias
Benchmark externally to validate fairness and competitiveness
3. Pay Equity Analysis (Analyze)
Collect comprehensive pay data (base pay, bonuses, benefits) by gender and job category
Calculate key indicators:
Mean and median gender pay gaps
Bonus and benefit gaps
Gender distribution across pay quartiles
Identify unexplained pay gaps ≥5% and assess justification
Build methodology for equal pay for equal work/work of equal value assessments
Develop remedial action plans to address unjustified gaps
4. Employee Right to Pay Information (Involve)
Establish a formal procedure for employees to request average pay levels, broken down by gender, for comparable work
Define HR service levels (response deadlines) in case query handling is managed centrally and provide information in a clear, accessible format
Record all requests and responses to demonstrate compliance
Update employee handbooks and intranet to explain rights
5. Recruitment & Job Adverts (Transparency to the Candidate)
Prepare to include initial pay level or relevant pay range for the job advertised
Remove all salary history questions from recruitment
Train recruiters and hiring managers on transparency rules
6. Pay Reporting Obligations (Transparency to the State and Public)
(Employers with ≥100 employees; frequency depends on workforce size)
Establish reporting systems to produce pay gap data at required intervals
Prepare reporting calendar (every year or every 3 years, depending on size)
Determine whether reporting must be internal only or also filed with authorities/public
Share results with employees, works councils, and regulators as required
7. Training & Awareness (Capability Building)
Train HR and managers on Directive requirements and employee rights
Educate employees on how to request pay information
Run awareness sessions with leadership on compliance and reputational risks
8. Employee Communication & Social Dialogue (Engagement)
Engage with works councils or employee representatives where required
Provide staff with FAQs and communication on rights and processes
Embed transparency principles into company culture
9. Monitoring & Continuous Compliance (Sustainability)
Track national transposition deadlines (7 June 2026) and country-specific rules
Monitor potential lower thresholds or stricter requirements in local law
Conduct annual internal pay equity reviews, regardless of reporting deadlines
Document remedial actions and progress