Document pay progression by stating the factors that can move an employee's pay, defining what each factor means, identifying the evidence required, describing how the decision is made and recording who approves it. Common factors may include relevant experience, acquired skills, sustained performance, increased responsibility or another job-related criterion, but the employer should use only factors that are objective, gender neutral and consistently applied. Article 6 of Directive (EU) 2023/970 requires criteria used to determine pay, pay levels and pay progression to be easily accessible to workers and objective and gender neutral, subject to the Directive's specific rule allowing Member States to exempt employers with fewer than 50 workers from the pay-progression accessibility obligation.
Jurisdiction: European Union
Start With a Clear List of Factors That Can Change Pay
A pay progression policy should identify the factors that can move an employee through a salary range or to a different pay level. Depending on the role and structure, those factors may include relevant experience, acquired skills, sustained performance, professional qualifications, increased responsibility or progression through a defined service scale. The organisation should avoid leaving the list open-ended if managers can then invent new factors for individual cases. Each criterion should connect to the job or compensation framework and should be capable of being applied without direct or indirect sex discrimination.
Define What Each Criterion Means in Practice
A label such as experience or performance is too broad on its own. The employer should define the type of experience that is relevant, how much weight it carries and how it differs from simple length of service. If skills affect progression, the policy should identify which skills matter and how proficiency is demonstrated. If performance affects pay, the organisation should explain the rating framework and how results translate into progression. Clear definitions reduce the risk that managers apply the same word differently across teams and make it easier for workers to understand what is expected.
Specify the Evidence Required for a Progression Decision
A transparent rule should identify what evidence supports each decision. Evidence may include performance records, certification, documented skill acquisition, completion of a development milestone, expanded responsibilities or another objective record. Requiring evidence does not mean every decision must be mechanical, but it reduces dependence on memory or informal advocacy. The employer should also specify the review period and whether progression occurs automatically when conditions are met or requires a separate approval. Workers should not have to rely on knowing the right manager or asking at the right moment to receive consideration under the policy.
Document Who Decides and How Exceptions Are Approved
The progression framework should identify decision-makers and approval authority. A manager may recommend an increase, while HR or compensation verifies consistency with the salary structure. Exceptions should require a documented reason and appropriate approval rather than becoming a parallel unwritten system. The organisation should also record whether an exception is temporary or permanent and whether it affects comparable workers. Repeated exceptions can indicate that the formal progression rule is outdated or that managers are bypassing it. Exception data should therefore be reviewed as part of compensation governance rather than stored and forgotten.
Make the Criteria Understandable and Accessible to Workers
Article 6 is concerned not only with internal documentation but with worker access to the criteria used to determine pay, pay levels and pay progression. Employers should therefore write the policy in language workers can understand and make it available through an employee handbook, intranet, policy portal or another reliable channel. Accessibility does not require publication of every employee's salary. It requires transparency about the decision rules. The employer should also explain how workers can ask questions or challenge an apparent inconsistency without having to reverse-engineer the compensation system from individual outcomes.
Article 6 Requires Objective and Gender-Neutral Criteria
Directive (EU) 2023/970 requires employers to make the criteria used to determine pay, pay levels and pay progression easily accessible to workers and states that those criteria must be objective and gender neutral. Article 6 also allows Member States to exempt employers with fewer than 50 workers from the obligation to make pay-progression criteria easily accessible. That exemption does not turn subjective or discriminatory pay criteria into acceptable practice. Employers should therefore check the national implementation while maintaining objective documentation that can support equal-pay analysis and consistent decision-making.
Retain Decision Records So the Policy Can Be Audited
A written progression framework is only useful if actual decisions can be compared with it. Employers should retain enough information to reconstruct the employee's salary before the decision, the relevant range, the criterion relied on, the evidence, the increase or movement approved, the decision-maker and any exception. Periodic analysis can then test whether workers with similar evidence receive similar outcomes. Patterns by sex, manager, location or worker category may reveal that the documented policy is being applied unevenly even when the wording itself appears objective.
Frequently Asked Questions
What should pay progression criteria include?
They should identify the factors that can affect pay, define those factors, explain required evidence, describe the decision process and identify approval and exception rules.
Must workers be able to see pay progression criteria?
Article 6 generally requires criteria used to determine pay, pay levels and pay progression to be easily accessible to workers. Member States may exempt employers with fewer than 50 workers from the pay-progression accessibility part of that obligation.
Can performance and experience both be progression criteria?
Yes, where they are genuinely relevant, defined objectively, gender neutral and consistently applied. Employers should document how each factor is assessed and how it affects pay.
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.