What Data Goes Into a Joint Pay Assessment?

Start With the Proportion of Women and Men in Each Category

Article 10(2)(a) requires analysis of the proportion of female and male workers in each category of workers. This provides the workforce-composition context for the assessment. Employers therefore need a reliable mapping of workers into categories based on the same work or work of equal value framework used under the Directive. Category design should be non-arbitrary and based on objective, gender-neutral criteria. A weak category structure can undermine the usefulness of every later comparison because the assessment depends on meaningful groups of comparable workers.

Average Pay and Variable Components Must Be Available by Sex and Category

Article 10(2)(b) requires information on average female and male workers' pay levels and complementary or variable components for each category of workers. The assessment therefore needs more than base-salary data. Compensation data should be capable of distinguishing ordinary pay from bonuses, incentives and other complementary or variable components while preserving the category and sex dimensions needed for comparison. The exact operational calculation method may be clarified through national implementation or reporting guidance, but the Article 10 content requirement itself is explicit.

The Assessment Must Identify Category-Level Average-Pay Differences

Article 10(2)(c) requires the assessment to show any differences in average pay levels between female and male workers in each category. This is the central diagnostic output. An employer should be able to trace each identified difference back to the underlying worker population and pay data so that it can be tested for possible objective explanations or signs of inequity. Organisation-wide averages are not a substitute because Article 10 operates at category-of-workers level.

Reasons for Differences Need Evidence and Joint Establishment

Under Article 10(2)(d), the assessment includes the reasons for differences in average pay levels where any exist on the basis of objective, gender-neutral criteria. Those reasons are established jointly by workers' representatives and the employer. Data supporting a proposed explanation may therefore include job-evaluation records, documented experience or performance criteria, progression records, responsibility differences or other evidence relevant to the category. The Directive does not provide a closed list of valid reasons, so each explanation needs to be assessed against the objective and gender-neutral standard.

Article 10 Includes a Specific Post-Leave Pay-Improvement Measure

Article 10(2)(e) requires 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 during the period in which the leave was taken. Employers need enough historical pay and leave information to determine whether relevant improvements occurred and whether returning workers benefited. This requirement should not be replaced with a general absence or promotion statistic because Article 10 identifies a specific measure.

The Assessment Must Include Corrective Measures and Review Prior Measures

Article 10(2)(f) requires measures to address pay differences that are not justified by objective, gender-neutral criteria. Article 10(2)(g) also requires an evaluation of the effectiveness of measures from previous joint pay assessments. The data package should therefore support action as well as diagnosis. Employers should document the issue being addressed, the corrective measure, responsible owner, implementation status and evidence used to judge effectiveness. The Directive requires the content but does not prescribe one universal remediation-plan template.

Data Protection Applies to Joint Pay Assessment Information

Article 12 applies data-protection requirements to information processed under Article 10. Employers should therefore design the assessment so required analysis can be completed without unnecessary disclosure of identifiable worker pay. Member States may also restrict access where disclosure would directly or indirectly reveal an identifiable worker's pay, allowing access only to workers' representatives, the labour inspectorate or equality body. Data minimisation, controlled access and documented handling rules should be part of the assessment process.

Frequently Asked Questions

Related Guides

• identify pay differences by worker category
• joint pay assessments under the EU Pay Transparency Directive

Official Sources

• Directive (EU) 2023/970 - Article 10
• Directive (EU) 2023/970 - Article 12