A pay gap remediation plan should convert each unjustified difference identified in the joint pay assessment into a documented corrective action. Start with the affected worker category and root cause, specify whether the remedy is an individual pay correction, a structural change or both, assign ownership, identify dependencies, document the objective basis for the action and set a timetable that supports remediation within a reasonable period. Article 10 requires remediation in close cooperation with workers' representatives and also requires analysis of gender-neutral job evaluation and classification systems as part of implementing the measures.
Jurisdiction: European Union
Start With Confirmed Unjustified Differences
A remediation plan should begin with the findings of the joint pay assessment, not with a generic list of compensation initiatives. For each affected category of workers, identify the measured difference, the reasons examined, any objective gender-neutral explanations that were accepted and the remaining difference that requires correction. This creates a direct line between evidence and action and reduces the risk of applying broad adjustments that do not address the actual cause.
Match the Remedy to the Root Cause
Different causes require different solutions. A starting-pay inconsistency may call for individual salary corrections and tighter offer controls. A progression problem may require changes to promotion or merit criteria. A job-evaluation problem may require reclassification or redesign of the evaluation framework. A variable-pay issue may require changes to eligibility, target setting, calibration or discretion. The plan should therefore state why each action is expected to correct the identified difference.
Separate Individual Corrections From Structural Changes
Individual corrections address workers whose pay is currently inequitable, while structural changes reduce the risk that the same problem will recur. Many cases require both. Raising one worker's pay without correcting the underlying progression rule can recreate the gap in later cycles. Conversely, fixing a policy without addressing workers already affected may leave the existing inequity unresolved. The remediation plan should therefore identify immediate worker-level corrections and longer-term system changes separately.
Assign Owners, Evidence and Decision Controls
Each action should have a responsible owner and a defined evidence trail. Compensation may own salary corrections, HR may own progression rules, payroll may implement changes, legal may review the objective basis and worker representatives should be involved as required by Article 10 and applicable national law or practice. The plan should record approvals, implementation dates, affected populations and the data needed to verify that the action was completed correctly.
Set a Timetable That Supports a Reasonable Remediation Period
Article 10 requires unjustified differences to be remedied within a reasonable period. The Directive does not define one universal number of days for every remediation action, so the timetable should reflect the scale and complexity of the problem while avoiding unnecessary delay. Immediate salary corrections may be possible quickly, while system redesign can take longer. Where structural work takes time, employers should consider whether interim measures are needed to prevent ongoing inequity.
Verify the Result and Prevent Recurrence
A remediation plan should include a follow-up check rather than ending when the action is implemented. Employers should recalculate affected pay outcomes, confirm that individual corrections reached the right workers, test revised rules for consistent application and document whether the original cause has been removed. The results can also inform later Article 9 reporting and any future joint pay assessment. This creates a closed remediation cycle rather than a one-time adjustment exercise.
Frequently Asked Questions
What should a pay gap remediation plan contain?
It should identify the affected worker category, root cause, corrective measure, owner, timing, evidence and follow-up review.
Should remediation include both individual and structural actions?
Where both current worker outcomes and the underlying system contributed to the inequity, both types of action may be necessary.
Does the Directive set one fixed remediation deadline?
Article 10 requires unjustified differences to be remedied within a reasonable period. National law or practice may add more detail.
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.