EU pay transparency compliance that shows which gaps survive once you explain them — and answers every worker within the legal deadline
Every pay-information request answered within the legal deadline.
See one case, screen by screen ↓Software that helps an employer meet Directive (EU) 2023/970: answering workers' pay-information requests within two months, grouping jobs of equal value, and reporting gender pay gap indicators. EU Pay Transparency Compliance adds seven agents that propose categories, explain each gap with cited objective factors, check small groups and draft every answer and country report, for the Head of Reward to decide and sign.
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Under Directive (EU) 2023/970 any worker can ask, in writing, for their own pay level and the average pay of women and men doing the same work or work of equal value — and the answer is due within two months. Each one needs the right comparison group, full-time-equivalent pay for the period, base and variable pay split by sex, a check that no colleague's pay can be worked out, and a letter in the worker's language. Reward teams build that by hand, request by request, while the clock runs.
The harder question is the gap itself. Which jobs are of equal value on skills, effort, responsibility and working conditions — and which part of each category's gap do objective, gender-neutral factors explain? From June 2027 employers with 250 or more workers report seven indicators a year, and a category with a gap of 5% or more that is not justified and not fixed within six months means a joint pay assessment with workers' representatives. Done country by country in spreadsheets, the explanation is rarely tied to the policy that pays each factor — which is exactly what a works council asks to see.
Estimated split for one worker's request at a multi-country employer, by hand and with the solution.
Seven agents group jobs of equal value, explain each gap with cited factors and draft every answer; the Head of Reward approves and signs.
Northwind Bio has 8 EU entities, 5,920 workers and 53 worker categories. It is Wednesday 7 October 2026; the pay snapshot runs to 30 September and the first gap reports are due on 7 June 2027. Here is what happens, screen by screen, in the working solution.
Priya's home screen is not a greeting but a chart: every category of workers doing work of equal value, one dot per category sized by headcount, one lane per country, against a dashed 5% line. On the raw gap, 13 categories are at 5% or more — packaging and warehouse operators in the Netherlands highest at 11.4%. The first gap reports are 243 days away.
“A gap of 5% or more that objective, gender-neutral factors do not explain — and that is not fixed within six months of the report — means a joint pay assessment with the works council.”
She presses Once explained. Each dot slides left by the points that approved factors account for — shift premium, allowances, scale steps, role size and territory — leaving a dashed ghost where the raw gap was. Five categories stay over the line: packaging and warehouse operators NL 6.8%, commercial field DE 6.1%, managers NL 5.6%, managers IT 5.3%, engineers and validation IE 5.2%.
“Still over the line once explained — each needs a remedy within six months or a joint pay assessment.”
For packaging and warehouse operators, the forklift licence allowance explains 2.7 points and the cold-store allowance 1.9. Each carries a citation; one click opens the Netherlands allowances policy, section 5: €85 a month for employees who hold a valid licence and drive reach trucks, €60 a month for work in 2–8 °C areas for at least half of their shifts.
“Allowances are paid at the same rate to everyone who meets the condition.”
The grouper scored both jobs from their job descriptions: packaging operators 312 points, warehouse operators 318 — 1.9% apart, inside the ±5% band. Packaging operators average €31,450 base pay and are 79 women and 13 men; warehouse operators €37,650 and are 17 women and 75 men. As one category the gap is 11.4%; the two allowances explain 4.6 points, and a 2019 market premium of 2.1 is not counted, leaving 6.8%. The works council asked for exactly this comparison.
The agents propose; they never decide. Lena Ortiz (HR legal) and Omar Haddad (works council) are consulted on Priya's decision.
Eleven requests are open, each with its comparison group, stage and days left: the works council's request for 14 packaging operators is due 20 October and waits on the category decision; Jonas Weber's in Germany is flagged as a small group. Anna Visser, QC analyst II in Leiden, asked through the HR portal on 29 September — due 29 November.
“Every worker may ask for their own pay and the average pay of women and men doing the same work or work of equal value. Each answer is due within two months.”
Request intake logs Anna's request and starts the clock. Category match places her in NL-C04 Quality professionals, 140 people, agreed with the works council. The pay gap calculator finds her base pay of €52,224 against group averages of €54,860 for women and €56,210 for men — a 2.4% gap between women and men, 7.2% on variable pay. The response writer drafts five sections — her pay, who she is compared with, the averages, how pay is set and grows, her rights — with six citations.
“Pay is inside the published range. Anna is on step 5 of 10 in grade 7 (€47,600–€61,900).”
The privacy guard confirmed 88 women and 52 men — above the minimum of 5 each, so no colleague's pay can be worked out. Priya checks the letter against its sources and signs: “I approve this response as accurate and complete.” The answer goes to Anna through the HR portal, with an English copy kept on file.
The request moves to Sent: answered in 8 days of the 61 the law allows. The signed letter can be downloaded, and every passage the answer rests on — the request, the pay snapshot, the category, the averages, the pay policy, Articles 7 and 12 — stays with it, read-only.
“Sent Oct 7 through the HR portal · answered in 8 days of 61.”
Jonas Weber, a medical director in Frankfurt, asked through the HR mailbox. His group, DE-C13 medical directors, has 5 women and 2 men: the averages would reveal a colleague's pay. The privacy guard stops the answer and offers the options the law allows — share the averages with the works council (Betriebsrat) only and tell Jonas he can check them there, share them with the national equality body on request, or give the grade range and his position in it without averages.
“Nothing is shared until Lena Ortiz confirms.”
The Netherlands gap report for 2026 pay shows the indicators the Directive asks for: mean gap 8.6%, median 6.2%, variable pay mean 14.1% and median 11.0%, variable pay received by 61% of women and 68% of men, and women 54% of the lowest pay quartile but 39% of the highest. Each category's gap is shown raw and explained. The approval chain runs Head of Reward, HR legal, works council, then Dana Okafor, managing director, who signs before filing by 7 June 2027.
The same gaps and requests, seen by the four people who carry them — what their year looked like, and what it looks like now.
Seven agents group jobs of equal value, explain each gap with cited factors and draft every answer; the Head of Reward approves and signs.
Reads every job description and pulls the facts that decide equal value — skills, effort, responsibility and working conditions — each with the passage it came from.
Watches the transposition of the Directive in each of the eight countries — thresholds, answer times, works council rights — and proposes rule changes for HR legal to approve.
Scores each job on skills (30%), effort (20%), responsibility (30%) and working conditions (20%) and proposes categories of equal value within the band, explaining why jobs belong together.
Computes the seven indicators of Article 9 and the averages a worker is entitled to — base and variable pay, full-time equivalent, mean and median, quartiles.
Explains each category's gap only with objective, gender-neutral factors — shift premium, allowances, scale steps, role size — and shows what stays unexplained.
Checks every answer and report for groups small enough to reveal a colleague's pay, and routes them to HR legal with the options the law allows.
Drafts each pay-information answer from the approved template in the worker's language, and each entity's gap report section by section, with citations.
Approves; HR legal agrees categories. The agents propose; a named person decides.
Ask about any request, category, gap or country rule — or say what to change. Every answer shows the passage behind it.
Which categories could trigger a joint pay assessment?
Five categories stay at 5% or more once objective factors are taken out — 13 before: packaging and warehouse operators NL (11.4% raw, 6.8% left), commercial field DE (8.3%, 6.1%), managers NL (7.9%, 5.6%), managers IT (7.4%, 5.3%) and engineers and validation IE (8.1%, 5.2%). If these are in the June 2027 reports and not fixed within six months, each needs a joint pay assessment with the works council.
Draft the reply to Anna Visser
Anna Visser (QC analyst II, Leiden) asked on Sep 29 — due Nov 29. Her group is Quality professionals, grades 7–8: 88 women and 52 men, so it is safe to share. The letter will show her base pay of €52,224 against averages of €54,860 for women and €56,210 for men — a 2.4% gap. The draft is in Dutch and English for you to sign.
Are packaging and warehouse operators work of equal value?
The agents say yes. Packaging operators score 312 points and warehouse operators 318 — 1.9% apart, inside the ±5% band. Packaging is higher on skills and responsibility (line speed, visual inspection, batch reconciliation); warehouse is higher on effort and working conditions (loads, cold store, forklift traffic). Forklift and cold-store allowances explain 4.6 points of the 11.4% gap; 6.8% is left. The 2019 market premium is not counted: no evidence it still applies.
How do we protect colleagues in small groups?
The privacy guard checks every answer before it leaves: each sex needs at least 5 people in the group. Today one category is below: medical directors, Germany (5 women · 2 men) — Jonas Weber's request is with Lena Ortiz. The law lets us share those averages only with worker representatives, the labour inspectorate or the equality body. The suggested answer: share with the works council and tell Jonas he can check there.
13 screens from the working solution, on its sample data. Pick one to see it large.
What counts as an explanation, who signs and how small a group may be are settings — applied to every request, versioned and audited.
| Setting | Default | Choose from |
|---|---|---|
| Our answer target | 30 days | Step up or down — the Directive allows two months |
| Smallest group we share | 5 per sex | Step up or down — smaller groups go to HR legal |
| Letter language | Language of the request, English copy for the file | On · Off |
| Tell every worker about the right once a year | Annual notice through the HR portal, every January | On · Off |
| Equal-value band | ±5% | Step up or down on job evaluation points |
| Allowed explanations | Shift premium, forklift licence and cold-store allowances, step on the pay scale, size of role, territory size — market premium off | On or off for each factor |
| Approves and e-signs every answer | Priya Raman | Priya Raman · Country HR lead |
| Where requests arrive | HR portal, HR mailbox, works councils and representatives | Each channel on or off |
Every figure is labelled: a target the solution is built to, an estimate, a typical published result, or a proven one.
“demo” = seen in the working solution, on its sample pay data · “target” = the design goal, measured in the live solution · “estimated” = our estimate · “typical” = published figures (Directive (EU) 2023/970, Articles 4, 7, 9, 10 and 12 — two months to answer a pay-information request, the 5% threshold for a joint pay assessment). People, companies and figures named on this page are fictional — characters and sample data in the working solution.
Software that helps an employer meet Directive (EU) 2023/970: answering workers' pay-information requests within two months, grouping jobs of equal value, and reporting gender pay gap indicators. EU Pay Transparency Compliance adds seven agents that propose categories, explain each gap with cited objective factors, check small groups and draft every answer and country report, for the Head of Reward to decide and sign.
Five agents log the request and start the two-month clock, place the worker in their category of equal value, compute their pay and the averages for women and men, check the group is large enough to share, and draft the letter in the worker's language with an English copy. The Head of Reward reviews the letter against its sources and e-signs it.
The job content reader pulls skills, effort, responsibility and working conditions from each job description, quoting the passage. The equal-value grouper scores the four factors with the agreed weights and proposes jobs within the band as one category. HR legal agrees each category after consulting the works council.
The raw gap compares women's and men's average pay in a category. The gap explainer then takes out only factors approved in Settings — such as shift premium, allowances, scale steps, role size or territory — each cited to the policy that pays it, and shows what is left. A factor without evidence, like the 2019 market premium in the sample, is not counted.
The privacy guard is built to prevent it. It checks that each sex in the group has at least the minimum set in Settings — 5 by default. Below that it stops the answer and sends it to HR legal with the options Article 12 allows, such as sharing the averages with the works council only.
Yes. The pay gap calculator computes the indicators for each entity and the report writer drafts the national report section by section from its template, with citations. It goes to the Head of Reward, HR legal and the works council, and the entity's managing director signs it.
Yes. The agents propose categories, explanations and drafts; they never send an answer or change a rule. The Head of Reward approves and e-signs every answer and decides remedies, HR legal agrees categories and small-group answers, and managing directors sign country reports.
The Agentic Solution Engine builds and deploys it from your requirements and documents — your job descriptions, pay policies, a pay snapshot and each country's rules — and it goes live once every quality gate has passed. We will walk you through it on your own data first.
Only the people a change touches retrain, all before it takes effect
1-min demoGxP Training ComplianceAn inspector's training question answered with cited records in minutes
1-min demoHR Policy Self-ServicePolicy answers for each employee's own country in seconds, clause quoted.
1-min demoWe'll run EU Pay Transparency Compliance on a sample of your own job descriptions, pay snapshot and requests.