Article 9(6) states that the accuracy of the gender pay gap reporting information must be confirmed by the employer's management after consulting workers' representatives. Workers' representatives must also have access to the methodologies applied by the employer. The Directive does not identify a single mandatory job title such as the CEO, CFO or HR director as the signatory. Employers should establish an internal governance process that produces reliable calculations, documents the methodology, records consultation and assigns the appropriate management confirmation in line with national implementing rules.
Jurisdiction: European Union
Management Confirms the Accuracy of the Information
Article 9(6) assigns the accuracy confirmation to the employer's management. The reporting process should therefore produce enough evidence for management to understand what is being confirmed, including the reporting population, pay-component mapping, calculation methodology, worker-category logic and quality checks. The Directive does not name one universal executive role that must provide the confirmation.
Confirmation Comes After Consulting Workers' Representatives
Article 9(6) states that management confirms accuracy after consulting workers' representatives. Consultation is therefore part of the reporting governance process, not an optional communication step added after sign-off. Employers should allow enough time for representatives to review the relevant information and methodology before final management confirmation.
Workers' Representatives Must Have Access to the Methodologies Applied
Article 9(6) gives workers' representatives access to the methodologies applied by the employer. A defensible methodology record should explain the reporting population, pay-component classifications, quartile construction, worker-category methodology and calculation approach for the required Article 9 metrics.
National Law May Add Sign-Off or Submission Procedures
Because Directive (EU) 2023/970 requires national implementation, Member States may add procedural requirements around submission, responsible entities, forms, declarations or reporting portals. Employers should treat Article 9(6) as the EU baseline and check the applicable national law before finalising the sign-off workflow.
Frequently Asked Questions
Who confirms the accuracy of Article 9 reporting information?
The employer's management confirms the accuracy after consulting workers' representatives.
Do worker representatives have access to the calculation methodology?
Yes. Article 9(6) states that workers' representatives shall have access to the methodologies applied by the employer.
Does the Directive require the CEO personally to sign the report?
No universal executive job title is specified. National law or internal governance may determine the responsible management sign-off.
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.