Reviewing pay progression during a joint pay assessment means examining how workers moved to higher pay levels and whether the criteria and decisions were applied consistently to female and male workers in the affected categories. Article 6 requires criteria used to determine pay, pay levels and pay progression to be objective and gender neutral. The review should examine promotions, merit increases, skills-based movement, seniority, performance ratings and discretionary adjustments where relevant. Article 10 also requires the assessment to consider the proportion of female and male workers who benefited from pay improvements after returning from maternity, paternity, parental or carers' leave where such improvements occurred in the relevant category during the leave period.
Jurisdiction: European Union
Pay Progression Can Create a Gap Even When Starting Pay Is Similar
Gender pay differences can develop over time even where female and male workers enter a category at similar pay levels. Differences in promotion rates, salary-range movement, performance increases, market adjustments, skills-based increases or discretionary decisions can compound across several years. A joint pay assessment should therefore examine the path workers followed through the pay structure, not only the current endpoint. Historical progression records can show where the gap began to widen.
Article 6 Requires Objective, Gender-Neutral Progression Criteria
Article 6 requires employers to make easily accessible the criteria used to determine workers' pay, pay levels and pay progression, and those criteria must be objective and gender neutral. Recital 35 notes that progression criteria can include individual performance, skills development and seniority. During a joint pay assessment, employers should test whether the criteria actually used match the documented criteria and whether comparable female and male workers were assessed using the same standards.
Review Promotions and Movement Through Pay Ranges
Promotion and salary-range movement should be analysed by worker category, sex and relevant objective factors. Employers should identify whether one group waited longer for progression, received smaller increases, entered new grades at lower points or was more likely to require exceptional approval. Differences may be justified where objective, gender-neutral factors explain them, but repeated patterns of discretion or inconsistent rule application require closer examination because they can create structural pay inequity.
Test Performance and Skills-Based Decisions
Where performance ratings or skills development affect pay progression, the employer should review whether rating standards, access to development opportunities and evidence requirements were applied consistently. A nominally neutral performance system can still create unequal outcomes if comparable achievements are evaluated differently or one group has less access to assignments that lead to higher ratings or skills premiums. The purpose of the joint pay assessment is to determine whether the resulting pay difference is supported by objective, gender-neutral evidence.
Include Pay Improvements Connected With Return From Leave
Article 10 requires the joint pay assessment to include the proportion of female and male workers who benefited from any improvement in pay following their return from maternity or paternity leave, parental leave or carers' leave, where such an improvement occurred in the relevant category while the leave was taken. This helps identify whether absence for protected family-related leave interrupted normal progression or prevented workers from receiving increases that otherwise applied to their category.
Remediate the Progression Process as Well as the Current Pay Gap
Correcting current salaries without changing the progression process can allow the same gap to reappear. Where the joint pay assessment finds inconsistent or unjustified progression outcomes, remediation may include clearer criteria, documented promotion decisions, calibration of performance ratings, standard rules for salary placement, controls on exceptions and automatic review of increases missed during qualifying leave. Article 10 requires unjustified differences to be addressed and prevented, so the corrective action should target both the existing difference and the mechanism that produced it.
Frequently Asked Questions
What does pay progression mean under the Directive?
It refers to the process by which a worker moves to a higher pay level. Recital 35 notes that criteria can include performance, skills development and seniority.
Should promotions be reviewed in a joint pay assessment?
Yes, where promotion or salary-range movement may help explain differences in average pay within an affected worker category.
Does Article 10 address pay improvements after family-related leave?
Yes. The joint pay assessment includes the proportion of female and male workers benefiting from relevant pay improvements after return from maternity, paternity, parental or carers' leave where the improvement occurred in the category during the leave period.
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.