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How do you report the gender pay gap?

ByAnita Lettink

What do you need to report?

The Directive stipulates two types of reporting: you must report on the overall gender pay gap for the company as a whole. You must also report the gap per category of worker: for workers performing the same work or work of equal value.

For the overall pay gap you must report:

  • the overall mean and median gender pay gap;
  • the mean and median gender pay gap by complementary or variable components of pay;
  • the proportion of female and male workers receiving complementary or variable components;
  • the proportion of female and male workers in each quartile pay band

For category of worker you must report:

  • the mean gender pay gap between workers by categories of workers broken down by ordinary basic wage or salary and complementary or variable components of pay

How do you calculate the gender pay gap?

This one is straightforward: the Directive states that pay levels should be expressed as gross annual pay and the corresponding gross hourly pay. You can calculate the gender pay gap by comparing the average gross hourly earnings of male and female employees across the organization. You do this for basic pay and for complementary or variable components of pay. This calculation should be done separately for the overall worker population and for each category of worker as shown in the bullet lists above. The results are expressed as a percentage, the difference between the earnings of men and women.

You might see companies report a positive and a negative pay gap. A positive pay gap indicates that men earn more than women. A negative pay gap suggests that women earn more than men. It’s important to recognize that gender pay gaps can go in either direction; don’t assume that women are always paid less.

How will you communicate the findings of the pay report?

The overall pay gap should be filed with the government and will be available there. The national monitoring bodies are expected to provide an easily accessible website for companies to publish their gender pay gap, as is the case in several countries that already have pay gap legislation in place. Take a look at Egapro, the French pay gap website. You can also publish it on your own website and make it available to your workers. As the employer, you are encouraged to include an explanation of any gender pay differences or gaps you have found.

The category of worker pay gap will be filed with the government too. In addition, you must shared it with employees, their representatives and others upon request. The category of worker gap comes with the 5% limitation: if the gap is larger than 5%, the employer must explain it, go into remediation and/or perform a joint assessment.

Isn’t employee data private?

It is! So you must be mindful of data protection regulations, such as the GDPR, when handling employee data. You must ensure that individual employees cannot be identified from the pay gap reports. This is obviously important in the category of worker reporting. You might run into a situation where the groups are so small, that people can easily identify themselves and their colleagues. The Directive allows you to combine data to a degree that ensures privacy is maintained, such as by grouping employees.

Keep in mind: even though you are bound by privacy, the Directive also states that you can’t prevent workers from voluntarily sharing their salary information!

What is the deadline for submitting your initial pay gap report?

The EU has set the reporting deadline for companies with 150+ employees at June 7, 2027 (at the latest). So, watch your local legislation! 13 of the 27 EU member states already have pay reporting requirements in place. Of these, 11 have reporting thresholds for companies with fewer than 100 employees. The EU Directive specifically states that current standards can not be lowered on the base of the new Directive. If you are required by national law to report on the gender pay gap today, you must continue to do so.

The EU requires countries to transpose the Directive into law not later than June 7, 2026. It goes without saying that you should closely follow this, and adhere to the requirements and dates stipulated in the national law. My recommendation is that you don’t wait until you have the final details, but start working on this today: collect your data, run an initial report, and look at the findings. The direction is clear and the sooner you get a handle on this, the better you are prepared.

Do you have some examples of pay gap reports?

Because countries are working on local legislation, I don’t yet know what the reports will look like. Fortunately, we have some help: the United Kingdom has had a public pay gap reporting requirement since 2018. For inspiration, take a look at these reports:

You’ll immediately notice that they all report the same numbers in a slightly different way. From very brief to including progress updates. From numbers only to charts. I recommend you familiarize yourself with these reports and then decide in what direction you want to go. You have enough time!