Equal work, equal pay – The role of job evaluation systems in the EU Pay Transparency Directive

The new EU Pay Transparency Directive will come into force on 7th June 2026 – and with it, new obligations. Employers face the challenge of establishing fair, gender-neutral and transparent job evaluation systems in order to meet the requirements of the directive. We explain how companies can use their existing systems to meet the requirements of the EU Pay Transparency Directive in a smart and efficient way with the help of digital tools.

The Pay Transparency Directive brings greater transparency to recruitment processes, extended rights to information for employees and, for companies with 100 or more employees, comprehensive reporting requirements on the gender pay gap.

The reports must contain salary information on ‘groups of employees performing the same or equivalent work’ (L 132/22, 11.). Companies that do not yet use a gender-neutral job evaluation system are therefore faced with the major task of implementing one.

Equal work and work of equal value

The job evaluation system – i.e. the system used to evaluate, group and transparently describe activities – plays a central role in meeting the new requirements. This is because a system that describes activities within the company in a transparent and gender-neutral manner forms the basis for enabling fair comparisons and objectively justifying pay differences.

The Pay Transparency Directive requires employers to divide the jobs in their company into groups of equal work and work of equal value.

Work is considered to be equal if the activities are identical or largely identical – in other words, if the occupations and requirements are very similar.

Work of equal value, on the other hand, refers to different activities that have the same value in terms of their requirements and demands.

Employers must ensure that they use job evaluation systems that are objective and gender-neutral.

Job evaluation and job architecture

Job evaluation criteria are used to systematically and objectively assess the requirements and complexity of a job, regardless of the person performing it. This allows jobs to be compared objectively with one another.

The EU has established four criteria for gender-neutral job evaluation. These are recommended by the International Labour Organisation (ILO) and the European Commission, among others, in guidelines on gender-neutral job evaluation and are widely used as evaluation criteria within EU Member States (ILO, 2008; European Commission, 2013). The criteria include

1. Skills

2. Effort

3. Responsability

4. Working Conditions

According to Article 4(4) of the Pay Transparency Directive, pay structures must be designed in such a way that comparable jobs can be identified on the basis of gender-neutral criteria. The EU Directive emphasises that relevant social skills must not be undervalued in this context. This is because so-called ‘typical female occupations’ in particular are disadvantaged if social skills such as communication skills or relationship building are not sufficiently taken into account when evaluating occupations.

Is my job architecture compatible?

Job architecture (also known as position architecture) is the overarching classification system for all positions within a company. It defines how activities, roles and hierarchies are systematically structured, based on objective job evaluation criteria. It forms the basis for transparent and comprehensible salary decisions and career opportunities, thereby contributing significantly to internal fairness. A clear job architecture contains objective job descriptions and is a prerequisite for a fair and transparent remuneration structure.

We know from experience that setting up a gender-neutral job architecture is complex and takes a lot of time and effort. Companies can use these resources elsewhere if they decide to use digital tools to create their job evaluation systems.

Solution: Use digital tools

We have developed a scientific system that can be used to examine and assign the equivalence of occupations without discrimination. This system is integrated into our PAY_transparency and FAIR_solution tools.

This makes it easy to precisely identify equivalent occupations and assign them to the corresponding employees in the company. All we need is the job code for each employee. We take care of the rest.

Once divided into groups of work of equal value, our tools generate the reports required by the directive in a legally compliant format. Companies can continue to use the structure created even after the analysis has been completed – for example, as a basis for developing or optimising their job architecture and remuneration structure.

Transparent and objective remuneration systems are the basis for fair remuneration structures. Our tools help to establish job evaluation systems in line with the EU Pay Transparency Directive – in order to report on the gender pay gap and all relevant indicators in a legally compliant format.