Part-time workers should not simply be excluded from pay equity analysis or compared using annual earnings alone. Directive (EU) 2023/970 defines pay level as gross annual pay and the corresponding gross hourly pay, and recital 22 allows the calculation to start from the worker's actual pay whether it is set annually, monthly, hourly or otherwise. Because a part-time worker can have lower annual earnings solely because they work fewer hours, hourly pay is often essential for understanding rate differences. Employers should preserve actual pay, working-time and FTE data, document any conversions, and apply the national reporting methodology consistently rather than automatically converting every worker to a full-time equivalent for every purpose.
Jurisdiction: European Union
Annual Earnings and Rate of Pay Are Different Questions
A part-time worker may earn less over a year simply because fewer hours are contracted. That does not automatically mean the worker receives a lower rate of pay. For pay equity analysis, annual earnings and hourly remuneration therefore answer different questions. Article 3 defines pay level using gross annual pay and the corresponding gross hourly pay, which supports viewing both dimensions. Analysts should avoid interpreting a lower annual figure as a pay-rate disadvantage until working time has been considered.
Keep Actual Pay and Working-Time Data Together
A reliable dataset should preserve the worker's actual gross pay together with contracted hours, FTE, employment dates and any other working-time field needed by the applicable methodology. Keeping these fields together makes it possible to calculate hourly measures, distinguish full-year from partial-year records and explain why two workers have different annual totals. If hours are missing or inconsistent, an apparently large pay gap may be a data-quality problem rather than a compensation difference. Source values should be retained even when transformed analytical fields are added.
Do Not Apply FTE Conversion Automatically
FTE normalisation can be useful for selected analytical questions, but it should not be treated as a universal replacement for actual pay. Converting every part-time worker to a full-time equivalent can answer a hypothetical question about annualised salary capacity, while the Directive also requires actual gross annual and corresponding hourly pay concepts. The method should therefore state which value is being used and why. National reporting rules may prescribe a specific treatment, and those rules should control compliance calculations.
Variable Pay Can Require Separate Part-Time Review
Part-time differences are not limited to base salary. Bonus eligibility, overtime access, commission opportunity and other complementary or variable components can be affected by working patterns. A worker may have the same hourly base rate as a full-time comparator but less access to assignments or thresholds that generate variable pay. Because Article 9 separately addresses complementary or variable components, analysts should examine whether part-time status affects eligibility, opportunity or calculation rules in ways that require further explanation.
Compare Part-Time Workers Within the Right Worker Category
Working time alone does not define the appropriate comparison group. The Directive's category-of-workers framework is based on the same work or work of equal value. Part-time and full-time workers may therefore belong in the same category when the work is comparable, although the pay measures may need working-time adjustment for interpretation. Analysts should avoid creating separate categories merely to remove a visible gap. Category design and working-time normalisation are different steps and should be documented separately.
Document Every Working-Time Transformation
A mature pay analytics process records the source pay value, source hours, FTE, conversion formula, reference period and resulting analytical value. It should also identify records affected by leave, mid-year starts, changed working patterns or other unusual circumstances. This makes the calculation reproducible and allows reviewers to see whether a reported difference comes from remuneration, working time or methodology. Where national instructions prescribe a different treatment, the national rule should be reflected in the compliance dataset and methodology notes.
Frequently Asked Questions
Should part-time workers be excluded from pay gap analysis?
No. Part-time workers remain within the Directive's worker scope. The analysis should account for working time and use the applicable annual and hourly pay measures consistently.
Should all part-time salaries be converted to full-time equivalent pay?
Not automatically. FTE conversion can support selected analytical questions, but compliance calculations should follow the applicable national methodology and preserve the Directive's actual annual and corresponding hourly pay concepts.
Why is hourly pay useful for part-time analysis?
Hourly pay helps distinguish a lower annual total caused by fewer working hours from a lower underlying rate of remuneration.
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Official Sources
Requirements and practices differ by jurisdiction and organisation. Check current local law, official guidance and professional advice for a specific situation.