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Method and EUPTD

How easygrading supports implementation of the EU Pay Transparency Directive

Five criteria, 28 grade levels, with a reason for every grading decision. This page explains how the model covers the four dimensions in Article 4(4).

As of: 19 October 2026

Legal statusMethodMappingWorking conditionsScopeIn practiceFAQ

In 30 seconds

  • The directive requires objective, gender-neutral criteria (Article 4(4)): skills, effort, responsibility and working conditions.
  • easygrading evaluates every job using five criteria and 28 grade levels.
  • Every grading decision is justified and documented.
  • easygrading supports implementation but does not replace a legal review.

What the directive requires and the current position in Germany

As of 19 October 2026 · Source: Official Journal of the EU (EUR-Lex) · Reviewed by: Dr. Viktor Beyfuß

Deadline and status

Directive (EU) 2023/970 entered into force on 6 June 2023. The transposition deadline expired on 7 June 2026. To the best of our current knowledge, Germany has not yet adopted implementing legislation; the existing German Pay Transparency Act continues to apply in the meantime. The Federal Ministry for Family Affairs plans entry into force in early 2027; German deadlines may differ from those in the directive.

This is the only page where we maintain detailed information on the legal status. The FAQ and home page link here.

Staggered reporting obligations under Article 9

EmployeesReports
250 or moreAnnually from 2027
150 to 249Every three years from 2027
100 to 149Every three years from 2031

Pay information before recruitment and the right to information apply regardless of size.

The five-criteria model

Building on the Paterson Method (Decision Band Method), implemented digitally. A job's value depends on the type and scope of the decisions it makes.

Where the method comes from

The Decision Band Method was developed by Scottish academic Thomas T. Paterson and has been used in analytical job evaluation for decades. easygrading makes this established logic available digitally and aligns it with the requirements of the EU Pay Transparency Directive. “Proven” refers to the method on which easygrading builds; it does not describe a standard or an official certification.

E

Decision-making

KF

Knowledge & skills

PL

Problem-solving

V

Responsibility

A

Impact

Every job is assigned to one of 28 successive grade levels using these criteria.

How the five criteria cover the four EU dimensions

The four legally required dimensions are integrated into the existing criteria framework rather than added as new criteria.

EU dimension (Article 4(4))Coverage in the easygrading model
SkillsKnowledge & skills (KF): breadth of knowledge, experience and social skills
EffortProblem-solving (PL): mental effort arising from complexity · Responsibility (V): effort arising from the burden of responsibility
ResponsibilityDecision-making (E), responsibility (V), impact (A): decision-making authority, planning horizon and effect on results
Working conditionsSupplementary module with two separately assessed scales (AB-1, AB-2); the reviewed result feeds into V

The working conditions module

Two scales are assessed separately. The displayed result is reviewed and used for V.

1

AB-1 Assess physical effort (operational and practical).

2

AB-2 Assess the demands of travel, time zones and working hours.

3

Review the displayed result and use it for V.

What easygrading does and does not do

Clear boundaries build trust.

easygrading provides

  • Job evaluation using five criteria and 28 grade levels
  • Salary bands for each grade (Pro)
  • Gender-specific pay analysis for each grade (Pro)
  • Comparable groups for information requests

easygrading does not provide

  • Legal advice
  • A guarantee that a company complies with the directive

Use cases for HR and the works council

Regrading jobs

Existing and new positions are graded consistently using the five criteria.

Internal pay transparency

Employees receive transparent, objective explanations of their grading based on documented criteria.

Works council discussions

A methodology applied consistently to all jobs makes it easier to agree on pay equity issues.

Common questions about the method

Is the EU Pay Transparency Directive already binding in Germany?

The transposition deadline expired on 7 June 2026. To the best of our current knowledge, Germany has not yet adopted implementing legislation; the existing German Pay Transparency Act continues to apply in the meantime.

Who is responsible for job evaluation?

HR is usually responsible, working with managers familiar with the jobs. Employee representatives should be involved early: in Germany, establishing pay principles is generally subject to the works council's co-determination rights (Section 87(1), no. 10, Works Constitution Act). An evaluation panel with several assessors grading jobs jointly has proven effective. This approach is part of the easygrading.de methodology.

Are the evaluation criteria documented?

Yes. Every evaluation step and criterion is transparently documented for each job. This enables you to explain to employees, the works council and in disputes which criteria were used to assign a job to its grade level.

Does job evaluation have to be documented?

The directive does not prescribe a specific documentation format. However, criteria for pay and pay progression must be easily accessible, and in disputes the burden of proof lies with the employer. Complete documentation of evaluations, criteria and reasons for decisions is therefore essential in practice. easygrading.de records the evaluation steps transparently for each job.

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