Yes. Different job titles can still represent work of equal value under EU equal-pay law. Article 4 of Directive (EU) 2023/970 focuses the comparison on objective, gender-neutral criteria such as skills, effort, responsibility and working conditions rather than on labels alone. A title difference may reflect organisational convention rather than a real difference in job value. Employers should therefore examine the substance of each role before excluding it from an equal-pay comparison.
Jurisdiction: European Union
Different Titles Do Not End the Comparison
An employer cannot safely conclude that two roles are incomparable simply because their job titles differ. Article 4 directs attention to the value of the work using objective, gender-neutral criteria. Titles can be useful shorthand, but they are created by organisations and may reflect history, local naming practice, status conventions or branding rather than the underlying demands of a job. Two roles with different names can therefore still require equivalent levels of skill, effort, responsibility and working-condition demands.
Job Content Matters More Than Naming Convention
A meaningful comparison looks at what the worker is actually required to do. Employers should examine core responsibilities, decision-making authority, knowledge requirements, interpersonal demands, problem-solving, workload and working conditions. A role called coordinator in one department might carry responsibility comparable to a specialist role elsewhere. Conversely, two jobs carrying the same title may differ materially in scope. The legal risk comes from using labels as a substitute for analysis rather than testing whether the work itself is of equal value.
Title Prestige Can Introduce Bias
Some job titles carry perceived status that can influence pay even when the underlying work-value evidence is weaker. Traditional occupational hierarchies may also assign more prestige to roles associated with one sex while under-recognising coordination, communication or care-related demands in another. A gender-neutral framework should reduce this risk by separating the evaluation criteria from organisational status signals. Relevant soft skills should be counted where they are genuinely required, and no role should receive extra value merely because its title sounds more senior or technical.
Different Titles Still Need Evidence of Equal Value
The fact that titles do not control the analysis does not mean every differently named job is comparable. Employers still need evidence that the roles are equivalent in value under the chosen criteria. One job may involve greater responsibility while another requires more specialised skill or more demanding conditions. A structured evaluation can show whether those differences balance out or lead to materially different job value. The correct conclusion should come from the evidence, not from a presumption that different titles are either always comparable or never comparable.
Use Consistent Evaluation Across the Organisation
Large organisations often use different title systems across departments, countries or acquired businesses. A central work-value framework can help identify roles that are comparable despite inconsistent naming. Employers should map jobs to common factors, document the rationale for evaluations and review apparent anomalies where similar work receives very different ratings. This approach is more defensible than relying on job-title families alone and can also improve salary-band design, pay-information responses and equal-pay investigations.
Frequently Asked Questions
Can two different job titles be compared for equal pay?
Yes. Different titles do not prevent comparison where the jobs are equal in value under objective, gender-neutral criteria.
Does a more senior-sounding title prove higher job value?
No. The value of the work should be assessed from job content and objective criteria rather than title prestige alone.
Can the same job title hide different job values?
Yes. Workers with the same title can still have materially different responsibilities or working conditions, so title identity is not conclusive either.
Related Guides
Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.