Jobs should be grouped into worker categories by looking at whether the workers perform equal work or work of equal value under objective, gender-neutral criteria. Under Directive (EU) 2023/970, this means grouping cannot be arbitrary or based only on titles, departments or historic salary grades. Employers should use reliable job information and a consistent evaluation framework covering skills, effort, responsibility and working conditions, then document why the resulting roles belong together for pay-transparency analysis.
Jurisdiction: European Union
Start With the Legal Concept of Comparable Work
A worker category should not be treated as a convenient HR label. The Directive links categories to workers performing equal work or work of equal value. That means the grouping exercise should begin with the substance and relative value of jobs. Employers should ask which roles are sufficiently comparable under the same objective framework before assigning them to a category used for information rights, reporting or equal-pay analysis.
Use Job Evaluation as the Analytical Foundation
A structured job-evaluation method can provide the evidence needed to group roles consistently. Scores, factor profiles or classification outcomes based on skills, effort, responsibility and working conditions can reveal which jobs are genuinely comparable. The exact method can vary by organisation, but the logic should be clear enough that an employer can explain why two roles belong in the same category and why another role does not.
Do Not Let Titles or Departments Decide the Category
Two jobs with different titles or in different departments may still be of equal value, while two jobs with the same title may have materially different responsibilities. Organisational labels can be useful evidence, but they should not replace analysis. Over-reliance on titles can preserve old structures and can hide comparisons between male-dominated and female-dominated work that has similar value.
Choose a Level of Granularity That Still Allows Meaningful Comparison
Categories that are too broad can mix jobs with materially different value, while categories that are too narrow can fragment the workforce and make pay comparisons meaningless. Employers should aim for groups that are coherent in job value while still large enough to reveal patterns. The correct level of granularity depends on the organisation, but it should be justified through evidence rather than selected to produce a preferred reporting result.
Test Categories Across Occupational and Gender Patterns
A useful bias check is to review whether worker categories track historical occupational segregation too closely. If female-dominated support, coordination or care roles are always separated from male-dominated technical or operational roles without a job-value reason, the grouping may deserve review. Cross-functional calibration can help reveal whether comparable work is being split by tradition rather than evidence.
Document and Revisit the Category Logic
The employer should preserve the job information, evaluation method and reasoning used to create each category. Categories should also be revisited when jobs change materially, when organisational structures are redesigned or when new evidence suggests that previously separate roles may be comparable. A documented review process makes the grouping more defensible and reduces the risk that outdated categories distort later pay analysis.
Frequently Asked Questions
What is a category of workers under the Pay Transparency Directive?
It is a non-arbitrary grouping of workers performing equal work or work of equal value, assessed using objective, gender-neutral criteria.
Can job titles define worker categories?
Titles can provide evidence, but they should not be the sole basis because differently titled roles can still be of equal value.
Should worker categories be reviewed?
Yes. Categories should be revisited when jobs, structures or evaluation evidence change materially.
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.