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employers must take action; at EU level, the “trigger” is commonly described around a 5% unexplained gap (driving remediation and, in some cases, joint assessment). 5. Reporting becomes a new compliance track (100+ employees): Pay-gap reporting phases based on headcount: the first reporting wave applies to larger employers, with later deadlines for mid-sized and smaller (down to 100 employees) employers. That means HR/payroll needs data readiness well before the first statutory reporting date. 6. More enforcement leverage: Documentation, remedies, and penalties: The directive strengthens enforceability (compensation and penalties/fines are part of the EU framework), so “good intentions” won’t be enough. Your processes need evidence trails.
Employees will be able to request information about their own pay level and average pay levels for comparable work.
2. A “no salary history” approach: The directive’s logic is to prevent past pay from anchoring future pay, so recruitment processes need to avoid questions and workflows that effectively recreate salary- history screening. 3. Employees gain a right to pay information: Employees will be able to request information about their own pay level and average pay levels for comparable work, progression. This demands job architectures and pay criteria that can withstand scrutiny. 4. Pay structures must be defensible, especially if gaps appear : If gender pay gaps are identified and cannot be justified with objective, gender-neutral criteria, broken down by gender, plus the objective criteria used for pay setting and
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GLOBAL PAYROLL MAGAZINE ISSUE 21
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