EU Pay Transparency Directive readiness: every pay-information request answered in days, every gap explained with evidence
Every pay-information request answered in days, every pay gap explained with evidence.
See one case, screen by screen ↓From June 2026 any worker can ask for their own pay level and the average pay of women and men doing the same work or work of equal value — in writing, within two months. Each answer 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.
Behind every answer sits the harder question: which jobs are of equal value. Reward teams score skills, effort, responsibility and working conditions job by job, explain each gap with objective, gender-neutral factors, and agree the categories with HR legal and the works council — across eight countries at different stages of putting the Directive into national law — one law in force, most still in draft. A category left at 5% or more, unexplained and not fixed within six months of the report, means a joint pay assessment.
Estimated split for a typical request, by hand and with the solution, in hours.
Specialist agents read every job, group work of equal value, work out and explain each gap, and draft every answer; the Head of Reward approves and signs.
Anna Visser, a QC analyst in Leiden, asks how her pay compares. The same morning, a works council request waits on whether packaging and warehouse operators do work of equal value. Here is what happens next, screen by screen, in the working solution.
Priya opens the desk and sees Northwind Bio as it stands: 5 of 53 worker categories over the 5% line once explained (13 before), 11 open requests with the next due Oct 20, 100% answered within two months at a median of 11 days, and 1 of 8 country reports signed. The first gap reports are due Jun 7, 2027 — 243 days away.
“Unexplained at 5% or more. Unless fixed within six months of the report, this needs a joint pay assessment with the works council.”
Anna asks for her own pay level, the average pay of women and men who do the same work or work of equal value, and how pay is set for her grade and how it increases. The request is translated from Dutch, the key phrases highlighted, and the two-month clock started: 53 days left of 61, due Nov 29.
Five agents check who is asking, place her in her category, compute her pay and the averages, check the group is large enough to share, and draft the answer.
Request intake confirms Anna (NW-NL-20417, Northwind Bio Nederland B.V.). 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 averages of €54,860 for women and €56,210 for men, a 2.4% gap. The privacy guard counts 88 women and 52 men, above the minimum of 5.
“Safe to share. The comparison group has 88 women and 52 men — above the minimum of 5 for each, so no colleague’s pay can be worked out.”
Alongside the draft, the agents check Anna’s position: step 5 of 10 in grade 7 (€47,600–€61,900). Her base pay is 4.8% below the women’s average in her group — consistent with 4 years in grade 7 against a group average of 6. Every figure links to the passage it comes from: the request, the pay snapshot, the category record, the averages, the pay policy, Articles 7 and 12.
Five sections: her pay level (base €52,224, variable €3,760, total €55,984), who she is compared with and how the group was formed, the averages for women and men — base and variable pay, and the share receiving variable pay (92% and 94%) — how pay is set and grows, and her rights. Full-time equivalent, for the 12 months to September 30, 2026, with six citations.
“Nobody is treated less favourably for asking.”
Priya reads the letter and its sources, then signs with her name and password, and the meaning of her signature: “I approve this response as accurate and complete.” The letter goes to Anna through the HR portal, an English copy stays on file, and the signature is recorded in the audit trail. Anna has her answer in 8 days of 61.
Jonas Weber, a medical director in Frankfurt, asked the same question. His group, DE-C13 Medical directors, has 5 women and 2 men; sharing the men’s average would reveal identifiable colleagues’ pay. The guard stops the answer and offers what the law allows: share the averages with the works council (Betriebsrat), share them with the national equality body on request, or give the grade range without averages.
“Nothing leaves the desk until Lena Ortiz confirms.”
Every job in the Netherlands is scored on skills (30%), effort (20%), responsibility (30%) and working conditions (20%). Packaging operators (€31,450 average base pay, 79 women and 13 men) and warehouse operators (€37,650, 17 women and 75 men) land 312 and 318 points — inside the ±5% band. The agents propose them as one category of equal value; a works council request for 14 packaging operators, due Oct 20, waits on it.
Each score quotes the job description: “Repetitive precision at up to 120 units a minute” against “Loads up to 23 kg with lifting aids; driving reach trucks”. The category would show an 11.4% gap. The forklift licence allowance explains 2.7 points and the cold-store allowance 1.9. The 2019 market premium is not counted — there is no evidence for each job — so 6.8% is left, above the 5% line.
Keeping the jobs separate needs objective evidence — under the Directive the employer must prove it.
Priya accepts the two jobs as one category; the works council (Omar Haddad) is consulted and HR legal (Lena Ortiz) confirms, so the works council request can now be answered. She tests a fix: raising packaging operators’ base pay by 4% from Jan 1, 2027 leaves 4.4% unexplained — under the 5% line — for €115,736 a year across 92 operators, 79 of them women.
The same request and the same category, seen by the five people who carry them — what their week looked like, and what it looks like now.
Specialist agents read every job, group work of equal value, work out and explain each gap, 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 country — thresholds, answer times, works council rights — and proposes rule changes with the passage.
Scores each job on the four factors with the agreed weights and proposes categories of equal value, 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 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 response 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 tell it 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. If these are in the June 2027 reports and not fixed within six months, each needs a joint pay assessment with the works council. The biggest is packaging and warehouse operators in Leiden — and that category is still waiting for your decision.
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.
Raise the smallest group we share to 7
Done — averages are now shared only when each sex has at least 7 people. One category is below that and will go to Lena Ortiz (HR legal) before any answer leaves the desk: DE-C13 medical directors (5 · 2). The change is versioned in Settings and recorded in the audit trail.
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; warehouse is higher on effort and working conditions. 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.
13 screens from the working solution, on its sample data. Pick one to see it large.
What differs between your entities, your policies and your works councils is a setting, not a project.
| Setting | Default | Choose from |
|---|---|---|
| Our answer target | 30 days | Any number of days inside the legal two months |
| Smallest group we share | 5 per sex | Raise or lower; smaller groups go to HR legal |
| Letter language | Language of the request, with an 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% | Wider or narrower, in job evaluation points |
| Factors that may explain a gap | Shift premium, forklift licence and cold-store allowances, step on the pay scale, size of role, territory size | Each on or off · market premium off until there is evidence for each job |
| Who approves and e-signs every answer | Priya Raman | Priya Raman · Country HR lead |
| Who signs each national report | Managing director of the entity | Managing director of the entity · Priya Raman |
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 data for a fictional employer, Northwind Bio, with 8 EU entities · “target” = the design goal, measured in the live solution · “estimated” = our estimate · Sources: Directive (EU) 2023/970, Articles 4, 7, 9, 10 and 12 · GDPR. People, companies and products named on this page are fictional — characters and sample data in the working solution.
Directive (EU) 2023/970 gives every worker the right to 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, answered within two months (Article 7). Employers report pay gap indicators (Article 9), and a category gap of 5% or more that is not explained by objective, gender-neutral factors and not fixed within six months leads to a joint pay assessment (Article 10).
The job content reader pulls skills, effort, responsibility and working conditions from each job description, quoting the passage. The equal-value grouper scores each job with your weights — 30, 20, 30 and 20% in the working solution — and proposes jobs within your band as one category. HR legal agrees each category after consulting the works council.
It places the worker in their category, computes their full-time equivalent pay and the averages for women and men, base and variable, checks the group is large enough to share, and drafts the letter from your template in the worker’s language with an English copy. The Head of Reward approves and e-signs before it is sent.
Yes. Averages are shared only when each sex in the group has at least the minimum you set — 5 in the working solution. Below that, the privacy guard stops the answer and sends it to HR legal with the options the law allows: share with worker representatives or the equality body, or give the grade range without averages.
The national rules watcher reads official journals and HR legal’s memos for each country weekly, and proposes changes to thresholds, deadlines and works council rights with the passage. No rule changes until HR legal approves it.
Yes. The agents propose and draft; people decide. The Head of Reward signs every answer, HR legal and the works council agree every category, HR legal decides every small-group answer, and each entity’s managing director signs its report. Every step is in the audit trail.
Payroll for base, allowances, variable pay and hours; your job descriptions and grades; your pay policies; the HR portal and HR mailbox where requests arrive; and the national rules for each country.
The Agentic Solution Engine builds and deploys it from your requirements — your job descriptions, pay policies, letter templates and a pay snapshot — and it goes live once every quality gate has passed. We will walk you through it on a sample of your own jobs and pay first.
Every SOP change retrains only the people it touches, all trained before it takes effect.
1-min filmTraining Evidence PackEvery inspector's training question answered with a cited evidence pack in minutes, each gap explained to QA first.
1-min filmHR AnswersEvery employee gets the policy answer for their own country in seconds, with the clause quoted.
1-min filmWe’ll run the Pay Transparency Desk on a sample of your own jobs and pay.