Employers should select job-evaluation factors that reflect the genuine demands of the jobs being compared and can be applied objectively across different occupational groups. Article 4 of Directive (EU) 2023/970 identifies skills, effort, responsibility and working conditions as the core criteria and allows other relevant criteria where appropriate. Factor selection should therefore start with those core dimensions, test whether they capture the organisation's full range of work, define each factor clearly and check whether any important demands common in female-dominated or male-dominated roles have been omitted or duplicated.
Jurisdiction: European Union
Start With the Four Article 4 Criteria
Skills, effort, responsibility and working conditions provide the legal baseline for work-of-equal-value assessment under the Directive. Employers should ensure each dimension is represented in the methodology and defined broadly enough to capture different forms of work. Relevant additional factors can be used where they add genuine analytical value, but they should not simply duplicate the core criteria under different names.
Choose Factors That Apply Across the Workforce
A factor framework should work for technical, operational, administrative, care, professional, managerial and support roles. If a factor only makes sense for one occupational family, it may distort comparisons across the organisation. Employers should test proposed factors against a representative sample of roles before finalising the methodology.
Define Each Factor Precisely
Factors should have clear boundaries so evaluators know what belongs under each one. Ambiguous factors create double counting and inconsistent scoring. Definitions should describe the job demand being measured, the evidence that supports it and the distinction between lower and higher levels.
Look for Missing Forms of Work
A gender-neutral review should ask whether the proposed framework captures interpersonal skill, emotional demands, coordination, safety accountability, physical demands, technical complexity and other material forms of work. Omitting a demand because it is common in a particular occupation can systematically depress the value assigned to that work.
Avoid Double Counting
Related concepts should not be rewarded repeatedly unless the methodology has a clear reason for doing so. For example, decision complexity might appear under both skill and responsibility if definitions are vague. Double counting can skew job values and make the system harder to explain. A factor map can help identify overlaps before scoring begins.
Validate the Framework Before Full Rollout
Employers should pilot the factors on a diverse group of jobs, compare outcomes across occupational groups and involve people with knowledge of the roles. Worker representatives should be involved where required by the applicable framework. Unexpected patterns should trigger review of factor definitions, evidence or weighting before the methodology is used broadly.
Frequently Asked Questions
Which factors does EU pay-transparency law require?
Article 4 identifies skills, effort, responsibility and working conditions as the core criteria for assessing work of equal value.
Can employers use additional job-evaluation factors?
Yes, where they are relevant, objective and gender-neutral. The Directive does not impose one universal factor architecture.
How can employers test whether factors are biased?
They can pilot the framework across male-dominated, female-dominated and mixed roles and review whether important job demands are omitted, duplicated or inconsistently valued.
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.