Yes. Managerial and non-managerial roles can potentially be compared for equal-pay purposes if the work is equal or of equal value. Directive (EU) 2023/970 applies to workers in management positions and requires work value to be assessed using objective, gender-neutral criteria such as skills, effort, responsibility and working conditions. A manager may have greater people or decision-making responsibility, but a non-managerial specialist may carry equivalent value through technical complexity, financial accountability, safety duties, expertise or other substantial responsibilities. The correct question is therefore not whether both jobs sit at the same organisational level, but whether their overall value is comparable under a defensible methodology.
Jurisdiction: European Union
Management Status Does Not Automatically Decide Comparability
A managerial title can be relevant evidence about a role, but it is not a legal shortcut for deciding work value. The Pay Transparency Directive requires comparison using objective, gender-neutral criteria. Two jobs can sit at different levels on an organisation chart yet still warrant closer analysis if the total demands of the work are comparable. Employers should therefore avoid policies that automatically exclude non-managerial roles from comparison with managers without examining the substance of the jobs.
Responsibility Must Be Examined Broadly
Managers often carry people-management, budget or decision-making responsibility, but responsibility is broader than line management. Non-managerial specialists may be accountable for regulated systems, major customer relationships, technical architecture, financial controls, safety-critical work, sensitive data or high-value assets. A gender-neutral job-evaluation method should capture these forms of responsibility rather than awarding value only for supervising employees.
Skills, Effort and Working Conditions Still Matter
Work value is multi-factor. A management role may score highly on responsibility while a specialist role may require deeper technical skills, sustained cognitive effort or demanding working conditions. Employers should evaluate the full pattern of job demands rather than allowing one factor to dominate automatically. This is particularly important where historically male-dominated management tracks and female-dominated specialist or coordination roles have been valued differently for reasons that are not well documented.
A Comparison Does Not Guarantee Identical Pay
Even where roles are found to be comparable, a pay difference is not automatically unlawful. Employers may be able to justify differences using objective, gender-neutral criteria such as relevant experience, performance, competence or another legitimate factor that is applied consistently. The employer should be able to identify the reason, show how it was measured and demonstrate that it is unrelated to sex.
Employers Should Document Why Roles Are or Are Not Comparable
A defensible comparison should record the job information reviewed, the factors applied, the scoring or classification logic and the reasons for the conclusion. Generic statements such as 'managerial role' or 'professional role' are weak evidence on their own. Documentation becomes especially important when pay-information requests, joint pay assessments or equal-pay disputes require the employer to explain how categories of workers were constructed.
Frequently Asked Questions
Can a manager be compared with a specialist?
Potentially yes. The comparison should focus on the objective value of the work rather than the job title or reporting level.
Does managing people automatically make a job more valuable?
Not automatically. People management is relevant responsibility, but other roles may carry equivalent responsibility through technical, financial, safety or other accountability.
If jobs are comparable, must pay be identical?
Not necessarily. Differences may be lawful where they are supported by objective, gender-neutral reasons that are relevant and consistently applied.
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.