A joint pay assessment is a structured pay-equity review carried out by an employer together with workers' representatives under Article 10 of Directive (EU) 2023/970 when the Directive's trigger conditions are met. It examines gender distribution, average pay levels, complementary or variable pay, category-level pay differences, the reasons for those differences, relevant post-leave pay improvements, remedial measures and the effectiveness of previous assessments. Its purpose is to identify, remedy and prevent pay differences that cannot be justified by objective, gender-neutral criteria.
Jurisdiction: European Union
A Joint Pay Assessment Is More Than a Routine Pay Audit
Employers may already run voluntary pay audits for internal governance, but Article 10 creates a specific legal assessment with defined triggers, required content and worker-representative involvement. Once the conditions in Article 10(1) are met, the assessment is no longer simply an optional analytics exercise. It becomes part of the Directive's remediation framework. The employer must examine category-level pay outcomes, determine whether differences can be justified on objective, gender-neutral criteria and identify measures where they cannot.
The Assessment Focuses on Categories of Workers
The Directive's reporting and assessment framework operates at the level of categories of workers rather than relying only on an organisation-wide gender pay gap. That matters because a workforce can have an overall pay gap driven by occupational distribution while also having separate unexplained differences inside categories of workers performing the same work or work of equal value. A joint pay assessment therefore needs defensible categories and reliable data that allow female and male workers within each category to be compared on a consistent basis.
Article 10 Specifies the Evidence the Assessment Must Contain
The assessment must include the proportion of women and men in each category, average female and male pay levels and complementary or variable components, differences in average pay, reasons for those differences where objective and gender neutral, relevant post-leave pay improvements, remedial measures and an evaluation of previous measures. This creates an evidence chain from outcome to explanation to correction. Employers should preserve the underlying methodology and source data so the assessment can be reviewed and reproduced.
The Assessment Is Designed to Produce Remedial Action
The purpose stated in Article 10 is to identify, remedy and prevent unjustified differences in pay. A completed assessment should therefore lead to decisions, not just observations. Where a pay difference is not justified, the employer must address it within a reasonable period in close cooperation with workers' representatives. Depending on the cause, this may involve individual adjustments, revised salary ranges, corrected job classifications, changes to progression rules or revisions to variable-pay practices.
Frequently Asked Questions
Is a joint pay assessment the same as a voluntary pay audit?
No. A voluntary pay audit can be broader or differently structured. Article 10 creates a specific legal assessment with defined triggers, required content and worker-representative involvement.
What does a joint pay assessment examine?
It examines gender distribution, average pay, variable components, pay differences, reasons for differences, relevant post-leave increases, remedial measures and previous remediation effectiveness.
What is the main goal of the assessment?
To identify, remedy and prevent pay differences that are not justified by objective, gender-neutral criteria.
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.