Pay Transparency and Gender Pay Gap Report Template (EU 2023/970)

EU Pay Transparency Directive Art. 9-10 report: thresholds, categories of workers, seven indicators, 5% screen, joint pay assessment, remediation

HR & PersonalwesenVollständigDirective (EU) 2023/970 Arts 3-12, 18, 34; UK GPG Regulations 2017pay transparency gap reportAktualisiert 29.10.2026

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Anleitung: Use it when an employer prepares gender pay gap reporting under national law transposing Directive (EU) 2023/970. Fill the scope and national-law record and agree the categories of workers with workers' representatives before running numbers. The main pitfall is reporting only the headline gap, when the category-level gaps and their justification drive the joint pay assessment.

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Pay Transparency and Gender Pay Gap Report: [Employer entity], reporting year [YYYY]

Report and working file for an employer's gender pay gap reporting under the EU Pay Transparency Directive (Directive (EU) 2023/970, Articles 9 and 10): scope and deadline, pay structure and categories of workers, data and method, the seven indicators in Article 9(1), analysis by category of workers, the 5 percent screen that can lead to a joint pay assessment, remediation and the worker information duties of Articles 5 to 7. The Directive had to be transposed by 7 June 2026; the rights and duties apply through national law, which differs in timing and detail. A dated UK and US section shows comparable regimes. The example employer and all figures are fictional. Replace every [bracketed] value and every row marked Example. This is a documentation format, not legal advice; check the current national law and consult a qualified employment lawyer and your workers' representatives.

Document control

Field	Value
Document ID	[HR-PAY-2026-01] (Example)
Employer entity	[Kestrelvane Instruments, EU entity 1] (Example, fictional laboratory instrument maker in an EU Member State, part of the Kestrelvane Instruments Group)
Workers in scope	[640 workers on the reference date] (Example)
Reporting year (data period)	[Calendar year 2026] (Example)
Threshold band (Directive Article 9)	[250 or more: annual] (Example)
National law	[Name and number of the national transposition act, date checked]
Reporting authority	[Monitoring body designated under Article 29(3)]
Submission deadline	[7 June 2027, or the national date if different] (Example)
Version	[1.0]
Status	[Draft / Consulted / Confirmed by management / Submitted]
Owner	[@reward-lead]
Approvers/reviewers	[Managing director], [@chief-people-officer], [@data-protection-officer], [works council or workers' representatives]
Last updated	YYYY-MM-DD
Classification	[Confidential until submitted; sections 4.1 to 4.6 may be published]

Approvals

Role	Name	Decision	Date
Managing director (management confirmation, Article 9(6))	[@name]	[Accuracy confirmed]	YYYY-MM-DD
Workers' representatives	[Name]	[Consulted; methodology shared]	YYYY-MM-DD
Data Protection Officer	[@name]	[Reviewed suppression and access rules]	YYYY-MM-DD

Revision history

Version	Date	Author	Change
0.1	2027-02-15	[@author]	Example: data extract and categories agreed
0.9	2027-04-20	[@author]	Example: results and justification review after consultation
1.0	2027-05-28	[@author]	Example: confirmed by management and submitted

1. Scope, threshold and timetable
2. Pay structure and categories of workers
3. Data and method
4. Results: the seven indicators
5. Category review and the 5 percent screen
6. Joint pay assessment
7. Remediation plan
8. Worker information duties checklist
9. Consultation, confirmation and submission
10. Comparable regimes: dated UK and US examples
Glossary and references
Standard and licence note

1. Scope, threshold and timetable

1.1 Directive thresholds and first deadlines

Workers per employer	First report	Then	Data covered
250 or more	By 7 June 2027	Every year	Previous calendar year
150 to 249	By 7 June 2027	Every three years	Previous calendar year
100 to 149	By 7 June 2031	Every three years	Previous calendar year
Fewer than 100	Voluntary, unless national law requires pay information

Source: Directive (EU) 2023/970, Article 9(2) to (5). Member States may also compile indicators (a) to (f) themselves from administrative data (Article 9(8)); check whether your national system does this.

1.2 National transposition record

Member State	National act (number, date)	Status on date checked	Reporting authority	Date checked	Official source
[Member State of EU entity 1]	[Act]	[In force / adopted, not yet in force / draft]	[Authority]	YYYY-MM-DD	[URL]
[Member State of EU entity 2]	[Act]	[Status]	[Authority]	YYYY-MM-DD	[URL]

The transposition deadline was 7 June 2026 (Article 34). On 2026-10-30 the status per Member State should be taken from the national official journal or the Commission's national transposition measures page on EUR-Lex; do not rely on secondary trackers for a filing decision.

1.3 Scope decisions for this report

Decision	Choice	Reason
Workers counted	[All workers with an employment contract or relationship on [date], including part-time and fixed-term] (Example)	[National counting rule]
Reference period	[1 January to 31 December 2026] (Example)	Article 9: previous calendar year
Pay level used	[Gross hourly pay and gross annual pay, both reported]	Article 3(1)(b)
Entities	[EU entity 1 only; EU entity 2 has 310 workers and reports separately] (Example)	One report per employer

2. Pay structure and categories of workers

2.1 Job evaluation

Jobs are evaluated with [name of the job evaluation method], which scores each job on four factor groups: skills, effort, responsibility and working conditions, with relevant soft skills given proper weight. The method and its factor weights were reviewed with the works council on [date].

2.2 Categories of workers

Category ID	Category (jobs of equal value)	Evaluation score band	Women	Men	Total
CAT-01 (Example)	Operations and assembly	100 to 179	70	150	220
CAT-02 (Example)	Customer service and administration	100 to 179	80	30	110
CAT-03 (Example)	Technicians and field service	180 to 259	25	85	110
CAT-04 (Example)	Engineers and scientists	260 to 359	45	75	120
CAT-05 (Example)	Sales and account management	260 to 359	20	30	50
CAT-06 (Example)	Managers and senior specialists	360 and above	10	20	30
Total			250	390	640

Example note: CAT-01 and CAT-02 share a score band but are kept as separate categories because their working conditions differ (shift and line work against office hours). This choice was agreed with the works council; record the reason for every split or merge.

3. Data and method

3.1 Pay elements

Element	Basic pay	Complementary or variable	Excluded	Note
Base salary or wage	Yes			Contractual rate
Shift and on-call allowances		Yes
Annual bonus and commission		Yes		Cash paid in the reference year
Benefits in kind (company car, meal vouchers)		Yes		Taxable value
Overtime pay		[Yes / per national rule]
Expense reimbursements			Yes	Not pay
Employer pension contributions		[Per national rule]		Check the national definition

The Directive's definition of pay covers the basic wage or salary and any other consideration in cash or in kind (Article 3(1)(a)). National law may give a more detailed list; follow it.

3.2 Pay levels

Gross hourly pay is total gross pay for the period divided by paid hours in the period. Gross annual pay is total gross pay for the reference year, with part-year workers shown on an actual basis and, where national guidance asks for it, also annualised. The example uses hourly pay in EUR.

3.3 Formulas

Gender pay gap (mean), as defined in Article 3(1)(c):

gap = (average pay level of men - average pay level of women)
      / average pay level of men x 100

The median gap uses the median pay levels in the same formula (Article 3(1)(e)). Quartile pay bands split all workers, ranked by pay level from lowest to highest, into four equal groups (Article 3(1)(f)). A positive gap means women are paid less on average; a negative gap means men are paid less.

3.4 Data quality checks

Headcount reconciles to payroll and the HR system on the reference date (640 workers in the example).
Each worker is in exactly one category of workers.
Hours data present for every worker paid by the hour or with variable hours.
Sex recorded for every worker in line with national rules; record the method used and how missing values are handled.
Outliers (top and bottom 1 percent) reviewed, not removed.

3.5 Data protection

Pay data is processed under the GDPR, used only for applying equal pay (Article 12(2)) and reported in aggregate. Where a category is small enough that a figure could reveal one person's pay, national law may restrict access to workers' representatives, the labour inspectorate or the equality body (Article 12(3)). Record the suppression rule: [for example, figures for a sex with fewer than five workers in a category are shared only with workers' representatives]. Assess the processing in a DPIA (compliance/dpia) where your national authority expects one.

4. Results: the seven indicators

Example results for EU entity 1, reference year 2026, 640 workers (250 women, 390 men), hourly pay in EUR. Gaps are computed from unrounded averages; recomputing from the rounded figures shown can differ slightly, most visibly for small variable pay amounts in section 4.7.

4.1 Indicator (a): gender pay gap (mean)

Measure	Women	Men	Gap
Mean gross hourly pay, all elements (Example)	29.02	31.69	8.4%

4.2 Indicator (b): gender pay gap in complementary or variable components (mean)

Measure	Women	Men	Gap
Mean variable pay per hour, workers who received variable pay (Example)	2.58	3.27	21.0%

4.3 Indicator (c): median gender pay gap

Measure	Women	Men	Gap
Median gross hourly pay, all elements (Example)	23.70	26.79	11.6%

4.4 Indicator (d): median gender pay gap in complementary or variable components

Measure	Women	Men	Gap
Median variable pay per hour, workers who received variable pay (Example)	1.16	1.87	38.0%

4.5 Indicator (e): workers receiving complementary or variable components

Sex	Received variable pay	Workers	Share
Women (Example)	169	250	67.6%
Men (Example)	289	390	74.1%

4.6 Indicator (f): women and men in each quartile pay band

Quartile (hourly pay range, EUR)	Women	Men	Women share	Men share
Q1 lowest (19.10 to 22.13) (Example)	78	82	48.8%	51.2%
Q2 (22.18 to 24.94) (Example)	65	95	40.6%	59.4%
Q3 (25.02 to 39.85) (Example)	61	99	38.1%	61.9%
Q4 highest (39.87 to 70.71) (Example)	46	114	28.8%	71.2%
Total	250	390

4.7 Indicator (g): gap by category of workers, basic and variable pay

Variable pay here is averaged over all workers in the category, including those who received none, so that basic plus variable equals total average pay.

Category	Women	Men	Basic: women	Basic: men	Basic gap	Variable: women	Variable: men	Variable gap	Total: women	Total: men	Total gap
CAT-01 (Example)	70	150	20.96	21.50	2.5%	0.42	0.72	41.4%	21.38	22.22	3.8%
CAT-02 (Example)	80	30	22.36	22.59	1.0%	0.47	0.29	-60.9%	22.83	22.88	0.2%
CAT-03 (Example)	25	85	26.79	27.50	2.6%	1.06	1.41	24.7%	27.86	28.91	3.7%
CAT-04 (Example)	45	75	37.78	40.55	6.8%	2.43	3.46	30.0%	40.21	44.01	8.6%
CAT-05 (Example)	20	30	33.48	34.27	2.3%	7.30	9.25	21.1%	40.78	43.52	6.3%
CAT-06 (Example)	10	20	52.21	55.33	5.6%	8.76	8.53	-2.7%	60.97	63.86	4.5%

Indicator (g) goes to all workers and their representatives, and to the labour inspectorate and equality body on request (Article 9(9)).

4.8 Reading the headline result

Example interpretation: the mean gap of 8.4 percent comes mostly from the mix of women and men across categories: women are 28.8 percent of the top quartile and 48.8 percent of the bottom quartile. Within categories, total gaps range from 0.2 to 8.6 percent. Two categories reach the 5 percent screen (section 5). The variable pay gaps are larger than the basic pay gaps in every category except CAT-02 and CAT-06, which points to bonus and commission practices as an area to review.

5. Category review and the 5 percent screen

A joint pay assessment is required where all three conditions in Article 10(1) are met: the reporting shows a difference in average pay of at least 5 percent in a category of workers, the employer has not justified it on objective, gender-neutral criteria, and the employer has not remedied it within six months of submitting the report.

Category	Total gap	5% screen	Explanation tested	Justified?	Action	Deadline to remedy
CAT-04 (Example)	8.6%	Reached	Starting-pay supplements at hire went to more men; no objective criterion documented	No	Pay adjustment (section 7)	2027-11-28 (six months after submission on 2027-05-28)
CAT-05 (Example)	6.3%	Reached	Commission paid on documented territory sales results; territories allocation under review for indirect bias	Under review with works council	Decide by 2027-07-31; adjust if not justified	2027-11-28
CAT-06 (Example)	4.5%	Not reached	Basic pay gap 5.6% noted	Not required	Review at next pay round	Next pay round
CAT-01, CAT-02, CAT-03	0.2% to 3.8%	Not reached			Monitor

Workers, their representatives, the labour inspectorate and the equality body may ask for clarification of any figure, including reasons for differences, and the employer must give a substantiated reply within a reasonable time (Article 9(10)).

6. Joint pay assessment

Complete this section only if the screen in section 5 leads to a joint pay assessment. Record the content items of Article 10(2):

Item	Article 10(2) point	Content	Status
JPA-01	(a)	Share of women and men in each category of workers	[Reference section 2.2]
JPA-02	(b)	Average pay levels and variable components by sex for each category	[Reference section 4.7]
JPA-03	(c)	Differences in average pay by sex in each category	[Reference section 4.7]
JPA-04	(d)	Reasons for differences, if any, on objective, gender-neutral criteria, established jointly with workers' representatives	[Text]
JPA-05	(e)	Share of women and men who received pay improvements on return from maternity, paternity, parental or carers' leave, where improvements occurred in the category during the leave	[Figures]
JPA-06	(f)	Measures to address unjustified differences	[Reference section 7]
JPA-07	(g)	Evaluation of the effectiveness of measures from earlier assessments	[Text, or "first assessment"]

The assessment is made available to workers and their representatives, sent to the monitoring body and given to the labour inspectorate and equality body on request (Article 10(3)). Remedial measures include an analysis of the job evaluation and classification system, or setting one up (Article 10(4)).

7. Remediation plan

Action ID	Category	Action	Owner	Cost estimate	Due	Measure of success
REM-01 (Example)	CAT-04	Individual pay review of the 45 women engineers and scientists; adjust where pay is below peers of equal value	[@reward-lead]	EUR 226,008 a year (2.92 per hour x 1,720 hours x 45 workers, 0.67% of the paybill)	2027-09-30	Total gap in CAT-04 at or below 2.0%
REM-02 (Example)	All	End discretionary starting-pay supplements; offers within the published range, with reasons recorded	[@talent-acquisition-lead]	Process change	2027-07-01	Offers outside range: zero without approval
REM-03 (Example)	CAT-05	Audit territory allocation and commission plan for indirect bias with the works council	[@sales-director]	Internal time	2027-07-31	Decision recorded in section 5
REM-04 (Example)	CAT-06	Review basic pay positioning of women managers against range midpoints	[@reward-lead]	To be estimated	Next pay round	Basic gap below 5%

Example arithmetic: raising the average total hourly pay of women in CAT-04 from 40.21 to 43.13 (an increase of 2.92) brings the gap with men's average of 44.01 to 2.0 percent. At 1,720 paid hours a year, 2.92 x 1,720 = EUR 5,022.40 per person and EUR 226,008 for 45 workers, which is 0.67 percent of the entity's annual paybill of about EUR 33.7 million. Individual adjustments will differ; the figure is a budget envelope.

8. Worker information duties checklist

Duty	Directive article	Evidence	Status
Starting pay or range given to applicants in the vacancy notice or before the interview	5(1)	[Job posting template; ATS field]	[Done / Gap]
No questions on applicants' pay history	5(2)	[Interview guides, recruiter training record]	[Status]
Gender-neutral vacancy notices and job titles	5(3)	[Review log]	[Status]
Criteria for pay, pay levels and progression easily accessible to workers	6(1)	[Intranet page; career framework]	[Status]
Workers can request their pay level and category averages by sex; answered within two months	7(1), 7(4)	[Request form, response log]	[Status]
Annual reminder to all workers of the right to information	7(3)	[Communication date]	[Status]
No contract terms stopping workers from disclosing their pay	7(5)	[Contract template review]	[Status]
Information accessible to persons with disabilities	8	[Accessible formats]	[Status]

9. Consultation, confirmation and submission

Step	Date	Who	Evidence
Methodology shared with workers' representatives (Article 9(6))	2027-03-10 (Example)	[@reward-lead], works council	[Minutes]
Results and explanations discussed	2027-04-15 (Example)	Works council	[Minutes, written comments]
Accuracy confirmed by management (Article 9(6))	2027-05-25 (Example)	[Managing director]	[Signed confirmation]
Indicators (a) to (g) sent to the authority (Article 9(7))	2027-05-28 (Example)	[@reward-lead]	[Submission receipt]
Indicators (a) to (f) published on the website (optional, Article 9(7))	2027-06-01 (Example)	[Communications]	[URL]
Indicator (g) given to all workers and representatives (Article 9(9))	2027-06-01 (Example)	[@chief-people-officer]	[Intranet post]

Keep the analysis and evidence: on request, data for the previous four years, where available, must also be provided (Article 9(9)).

10. Comparable regimes: dated UK and US examples

10.1 United Kingdom

Employers with 250 or more employees on the snapshot date report six measures under the Equality Act 2010 (Gender Pay Gap Information) Regulations 2017: the share of men and women in each hourly pay quarter, the mean and median gap in hourly pay, the share of men and women receiving bonus pay, and the mean and median gap in bonus pay. The snapshot date is 5 April for private and voluntary sector employers (report by 4 April the following year) and 31 March for most public authorities (report by 30 March the following year). Bonus pay covers the 12 months ending on the snapshot date. GOV.UK guidance was updated on 21 May 2026 to record employee sex following the Supreme Court ruling on the meaning of sex in the Equality Act 2010. Action plans are voluntary for now; GOV.UK says that, subject to legislation, they will become mandatory from spring 2027.

10.2 United States

There is no federal duty to publish a gender pay gap. Private employers above set size thresholds file EEO-1 workforce demographic data with the EEOC; check the EEOC's current filing instructions and scope for the year. Several states and cities require pay ranges in job postings, for example New York State (Labor Law section 194-b, 4 or more employees), Washington (RCW 49.58.110, 15 or more employees) and California (Labor Code section 432.3, 15 or more employees). Some states also require pay data reports; check the state agency.

10.3 Reuse map

Item	EU Directive	UK regulations	Reuse note
Period	Previous calendar year	Snapshot date; bonus over 12 months to it	Separate extracts needed
Mean and median gap	(a), (c)	Mean and median hourly gap	Pay definitions differ
Variable or bonus gap	(b), (d)	Mean and median bonus gap	UK uses bonus pay only
Share receiving variable or bonus pay	(e)	Share receiving bonus	Close match
Quartiles	(f)	Hourly pay quarters	Close match
Category of workers	(g)	Not required	EU only

Glossary and references

Term	Meaning (paraphrased)
Pay	Basic or minimum wage or salary plus any other consideration in cash or kind received for the employment (Article 3(1)(a))
Pay level	Gross annual pay and the matching gross hourly pay (Article 3(1)(b))
Gender pay gap	Difference in average pay levels between women and men, as a percentage of men's average (Article 3(1)(c))
Median gender pay gap	The same comparison using median pay levels (Article 3(1)(e))
Quartile pay band	One of four equal groups of workers ranked by pay level (Article 3(1)(f))
Category of workers	Workers doing the same work or work of equal value, grouped non-arbitrarily on gender-neutral criteria (Article 3(1)(h))
Joint pay assessment	Assessment with workers' representatives to identify, remedy and prevent unjustified pay differences (Article 10)
Workers' representatives	Representatives under national law or practice

References (checked 2026-10-30):

Directive (EU) 2023/970 of the European Parliament and of the Council of 10 May 2023 to strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms, OJ L 132, 17.5.2023, Articles 3 to 12, 18 and 34: https://eur-lex.europa.eu/eli/dir/2023/970/oj
European Commission, new EU rules on pay transparency explained (5 June 2026): https://commission.europa.eu/news-and-media/news/new-eu-rules-pay-transparency-explained-2026-06-05_en
GOV.UK, gender pay gap reporting guidance for employers: https://www.gov.uk/government/collections/gender-pay-gap-reporting
GOV.UK, gender pay gap reporting and creating an action plan: https://www.gov.uk/government/collections/gender-pay-gap-reporting-and-creating-an-action-plan-guidance-for-employers
New York State Department of Labor, pay transparency: https://dol.ny.gov/pay-transparency
RCW 49.58.110: https://app.leg.wa.gov/rcw/default.aspx?cite=49.58.110
Related templates: Employee Handbook (hr/employee-handbook), Human Capital Report (hr/human-capital-report), Engineering Career Ladder (career/engineering-career-ladder), Job Description (career/job-description), Salary Negotiation Plan (career/salary-negotiation-plan).

Standard and licence note

Based on Directive (EU) 2023/970 (EUR-Lex, reusable under Commission Decision 2011/833/EU), cited by article and summarised in original wording, with UK government guidance (Open Government Licence v3.0) and US state sources (public) as dated comparisons. No legislative text is reproduced beyond short defined terms. National transposition laws set the binding rules and differ between Member States; the status and figures here reflect sources checked on 2026-10-30. The Kestrelvane Instruments example, its categories and all figures are fictional. Check the current national law and official guidance before reporting. This is a documentation format, not legal advice; consult a qualified employment lawyer and your workers' representatives. Template licence: MIT.