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Frequently asked questions

The EU Pay Transparency Directive requires objective, gender-neutral criteria for setting pay. A digital solution such as easygrading.de provides a systematic, transparent and documented approach to job evaluation as the foundation for this. easygrading.de helps companies implement the directive, but does not replace a legal review or guarantee compliance on its own. Companies that establish transparent jobs and salaries early also strengthen their position as fair employers in the competition for talent.

60 questions across 9 topics.

General information about the EU Pay Transparency DirectiveCompany obligations and requirementsPay transparency and the gender pay gapJob evaluation under the directiveImplementation and monitoringEmployee rightsDeadlines and transitional arrangementsOther important questionsDigital implementation

General information about the EU Pay Transparency Directive

1. What is the EU Pay Transparency Directive?

The EU Pay Transparency Directive (Directive (EU) 2023/970) aims to enforce the principle of equal pay for equal work or work of equal value and reduce the gender pay gap. It is initially addressed to Member States, which must transpose it into national law, where specific employer obligations arise. Its core elements include pay information before recruitment, employee rights to information, pay gap reporting, a joint pay assessment for unexplained differences, a reversal of the burden of proof in favour of employees, and effective sanctions.

2. When was the directive adopted and when does it apply?

The directive was adopted on 10 May 2023, published in the Official Journal of the EU on 17 May 2023 and entered into force on 6 June 2023. Member States had to transpose it into national law by 7 June 2026; that deadline has passed. We maintain the current status of implementation in Germany on the page Method and EUPTD.

3. Who does the directive apply to?

The directive applies to all employers in the public and private sectors, regardless of company size. This particularly concerns pay information before recruitment and employees' right to information. Pay gap reporting obligations, however, vary by size: they apply from 100 employees, with different deadlines and frequencies (see questions 6 and 31).

4. What is the main objective of the directive?

The aim is to enforce the principle of equal pay for equal work or work of equal value and reduce the gender pay gap. The directive relies on transparency: employees should understand the criteria used to determine pay, and employers must be able to explain pay differences. A transparent job evaluation provides the technical foundation for this.

Company obligations and requirements

5. What new obligations does the directive impose on employers?

Key obligations include pay information before recruitment (starting pay or a salary range), easily accessible criteria for setting pay and pay progression, information for employees about their pay and the average pay of comparable jobs broken down by gender, regular pay gap reporting from 100 employees, and a joint pay assessment if a gap of at least 5% is neither objectively justified nor remedied. Almost all these obligations require objective, gender-neutral pay criteria and therefore a sound job evaluation.

6. What are the reporting requirements?

Reporting obligations vary by employee count: employers with at least 250 employees report annually, first by 7 June 2027. Employers with 150 to 249 employees report every three years, also first by 7 June 2027. Employers with 100 to 149 employees report every three years, first by 7 June 2031. The directive does not require reporting below 100 employees. The German deadlines will depend on the implementing legislation.

7. What happens if a company does not comply?

Member States must establish effective, proportionate and dissuasive sanctions, which may include fines. Affected individuals are also entitled to compensation, and in disputes the burden of proof lies with the employer (details in question 37). Reputational damage may also have a negative effect on recruitment. The specific rules in Germany have yet to be established.

8. Do companies have to disclose their salary structures?

Not publicly, but to those concerned. Employers must make the criteria used to determine pay and pay progression easily accessible to employees and inform applicants of the starting pay or salary range. Employees can also request information about their own pay and average pay, broken down by gender, for comparable groups (question 24). A salary band for each job or grade helps provide consistent ranges for job advertisements and information requests.

9. What changes are there in recruitment?

Applicants are entitled to information about the starting pay or salary range for a job, based on objective, gender-neutral criteria. This information must be available before the interview, for example in the job advertisement. Job advertisements and job titles must be gender-neutral. Companies that have assigned their jobs to grades and salary bands can derive the range for each vacancy directly from its salary band.

10. Are employers allowed to ask about previous salary?

No. Employers may not ask applicants about their pay in current or previous employment. Starting pay should be based on the job and its evaluation rather than the applicant's salary history.

11. Must pay criteria be transparent?

Yes. Employers must make the criteria used to determine pay, pay levels and pay progression easily accessible to employees. These criteria must be objective and gender-neutral. In easygrading.de, the criteria are an integral part of the evaluation system and are transparently documented for each job.

Pay transparency and the gender pay gap

12. What is the gender pay gap?

The gender pay gap is the difference between the average pay levels of women and men, expressed as a percentage of men's average pay. A distinction is made between the unadjusted gap (all employees) and the adjusted gap, which compares employees performing equal work or work of equal value. Comparisons within groups of employees performing equal work or work of equal value are particularly important for the directive. This requires a job evaluation.

13. How is the gender pay gap measured?

The directive measures the pay gap using pay levels, meaning gross annual pay and the corresponding gross hourly pay, as an average and also as a median. Reports show the gap for the employer as a whole and for groups of employees performing equal work or work of equal value, with basic pay and variable components shown separately. Defining these groups requires a job evaluation.

14. Must companies take action if the gender pay gap is high?

Yes, but subject to conditions. If the report shows a gap of at least 5% within a group of employees which the employer cannot justify using objective, gender-neutral criteria and has not remedied within six months, the employer must carry out a joint pay assessment with employee representatives and establish remedial measures. The 5% threshold therefore does not trigger an automatic obligation to adjust pay. The key question is whether the difference can be objectively justified, which requires a transparent job evaluation.

15. What measures can companies take?

Possible measures include reviewing job evaluations and the assignment of employees to grades or reference jobs, adjusting salary structures and salary bands, correcting individual salaries, and targeted development programmes. Salary analysis in easygrading.de (Pro version) helps identify employees outside their salary band and other unusual patterns.

Job evaluation under the directive

16. What is job evaluation?

Job evaluation determines the relative value of a job using defined criteria; it does not assess the performance of the jobholder. In analytical job evaluation, each job is assessed against every criterion and the result assigns it to a value level. This creates comparable groups of jobs (grades) as the basis for fair and transparent salary structures.

17. Why is job evaluation important for pay transparency?

The directive compares pay for equal work or work of equal value. Whether two jobs are of equal value can only be established using objective, gender-neutral criteria (Article 4(4)). Job evaluation provides this foundation. It enables comparisons between different activities, forms the basis for salary bands and information requests, and helps objectively justify pay differences in disputes.

18. What criteria are used in job evaluation?

Article 4(4) of the directive names four criteria that must be considered: skills, effort, responsibility and working conditions. They must be objective and gender-neutral and, where employee representatives exist, agreed with them. easygrading.de evaluates each job against five criteria: decision-making (E), knowledge and skills (KF), problem-solving (PL), responsibility (V) and impact (A), assigning it to one of 28 successive grade levels. The four EU dimensions are mapped to these criteria. Working conditions such as physical effort or travel are recorded in a separate module specific to each role.

19. Does job evaluation have to be documented?

The directive does not prescribe a specific format. Because the employer bears the burden of proof in a dispute, complete documentation of the evaluation, criteria and reasons for decisions is essential in practice; easygrading.de records this for each job (question 58).

20. Who is responsible for job evaluation?

Usually HR works together with managers familiar with the jobs, ideally as an evaluation panel. The works council should be involved early because pay principles are subject to its co-determination rights (question 29).

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Implementation and monitoring

21. Who monitors compliance with the directive?

Member States must designate a monitoring body, and employees can also enforce their rights through the courts. Equality bodies and employee representatives can support them. The authority responsible in Germany will be determined by the implementing legislation, which is still pending.

22. Is support available to help companies implement the directive?

Yes. External remuneration consultants, specialist software and seminars offer support. easygrading.de provides software that enables companies to carry out job evaluations and salary analyses themselves without commissioning a consulting project. Companies that want additional guidance can book the implementation package with five days of advisory support.

23. What if national laws are less strict than the EU directive?

The directive sets minimum standards. Member States must implement them and may not fall below them, but can retain or introduce rules more favourable to employees. Until national implementing legislation is in place, the directive generally has no direct effect on private employers. However, it must be taken into account when interpreting existing law and may have direct effect on public employers after the transposition deadline.

Employee rights

24. What rights to information do employees have?

Employees have the right to request written information about their individual pay level and the average pay levels, broken down by gender, of groups performing equal work or work of equal value. The employer must respond within two months and inform all employees of this right annually. Information can also be requested through employee representatives or the equality body. Employees may also disclose their pay. Comparable groups can only be defined properly through job evaluation; easygrading.de supports this by assigning jobs to grades.

25. Can employees take legal action over discrimination?

Yes. Anyone who considers themselves disadvantaged by pay discrimination can seek compensation, including back pay. The directive makes enforcement easier by reversing the burden of proof: if the claimant presents facts suggesting discrimination, the employer must prove that none has occurred. This requires transparent criteria and a documented job evaluation.

26. Are employees protected against retaliation for requesting information?

Yes. Employees must not suffer disadvantage for exercising their rights under the directive, such as requesting information or bringing a claim. This also applies to employee representatives and people assisting employees. Dismissal or other adverse treatment in response is prohibited.

Deadlines and transitional arrangements

27. Are there transitional implementation periods?

The deadline for Member States to transpose the directive was 7 June 2026. The directive also provides staggered reporting deadlines: first by 7 June 2027 for employers with at least 150 employees and by 7 June 2031 for employers with 100 to 149 employees (question 6). German deadlines may differ from those in the directive; the current status is available on the page Method and EUPTD.

28. What should companies do now?

Companies should establish the foundations now rather than wait for German legislation. First: evaluate jobs using objective, gender-neutral criteria. Second: assign jobs to grades and salary bands. Third: check current pay in each grade for unusual patterns. Fourth: document criteria for pay and pay progression and involve the works council. easygrading.de supports these steps without a consulting project. The trial demonstrates the process using sample data.

Other important questions

29. What role do employee representatives play?

Employee representatives must be involved at several points: in agreeing evaluation criteria, in the joint pay assessment when a gap of at least 5% cannot be justified, and in reviewing pay structures. In Germany, the works council has co-determination rights when pay principles are established (Section 87(1), no. 10, Works Constitution Act). A transparently documented evaluation process makes coordination easier. The page “Method and EUPTD” describes use cases for discussions with the works council.

30. Are there exceptions to the directive?

There is no exception to the basic principle of equal pay for equal work or work of equal value; it applies to all employers. Individual obligations differ: reporting obligations start at 100 employees, and Member States may exempt employers with fewer than 50 employees from disclosing criteria for pay progression. Pay information before recruitment and the right to information apply regardless of size.

31. How often must gender pay gap reports be produced?

This depends on employee count: employers with at least 250 employees report annually, while those with 100 to 249 employees report every three years. Employers with fewer than 100 employees are not required to report under the directive. Member States may introduce stricter rules.

32. What data must the reports contain?

Reports include the gender pay gap (average and median), the gap in variable components such as bonuses, the proportion of women and men receiving variable components, the distribution of women and men across the four pay quartiles, and the pay gap within each group of employees performing equal work or work of equal value. Defining these groups requires job evaluation.

33. Can companies use external support for job evaluation?

Yes. Many companies use external remuneration consultants, specialist software, or both. The advantage of software such as easygrading.de is that the company evaluates its jobs itself using a consistent, transparent set of criteria and can review and adjust the results at any time. External guidance is optional, for example through the implementation package.

34. What if a company has no gender pay gap?

Reporting obligations apply whether or not a gap exists, as do the rights to information and the obligation to make criteria transparent. Only the joint pay assessment is unnecessary if there is no unexplained gap of at least 5%. Companies with a transparently documented job evaluation can explain the result, including to employees and the works council.

35. How is sensitive salary data protected?

Salary data is personal data and is subject to the GDPR. The directive explicitly requires processing in accordance with the GDPR, use of the data solely to apply the principle of equal pay, and restricted access where individual employees could be identified. Employers must therefore define purpose limitation, data minimisation, access rights and retention periods. For protection measures at easygrading.de, see question 50.

36. What benefits does the directive bring to companies?

It promotes a fair working environment, increases employer attractiveness and can strengthen employee retention. Companies that have systematically evaluated their jobs also gain a sound basis for salary decisions, job advertisements with salary ranges and information requests.

37. What sanctions apply to violations?

Member States establish sanctions that must be effective, proportionate and dissuasive and include fines. Affected individuals are also entitled to compensation, including back pay. The reversal of the burden of proof is crucial in practice: the employer must demonstrate that no pay discrimination has occurred. This requires a transparent, documented job evaluation. The German rules are still pending.

38. Where can companies find further information?

Companies can find information in the directive on EUR-Lex, from the European Commission, the German Federal Ministry for Family Affairs, employers' associations and specialist remuneration consultants. Information about the methodology used by easygrading.de and the mapping of criteria is available on the page “Method and EUPTD”.

Digital implementation

39. How can easygrading.de help implement the directive?

easygrading.de is a web application for job evaluation, salary analysis and salary band design. It primarily supports obligations based on job evaluation: objective, gender-neutral evaluation under Article 4(4), salary bands for each grade (Articles 5 and 6), comparable groups for information requests (Article 7), and gender-specific pay analysis for each grade (Articles 9 and 10). The directive's criteria are integrated into the evaluation model. Whether a company complies with the directive also depends on data quality, processes and the applicable national law.

40. What method is easygrading.de based on?

The Paterson Method (Decision Band Method), an analytical job evaluation method used for decades. Its core idea is that a job's value depends on the type and scope of the decisions it makes. easygrading.de evaluates each job against five criteria (decision-making, knowledge and skills, problem-solving, responsibility and impact) and assigns it to one of 28 grade levels. The origin of the method and its mapping to Article 4(4) are explained on the page “Method and EUPTD”.

41. How does job evaluation with easygrading.de work?

In brief, there are three steps: record the organisation and data, evaluate jobs, and review and adjust salaries. The application runs in the browser without local installation. Question 55 describes the full process, and the features are shown on the product page.

42. What are the advantages of digital job evaluation?

Digital evaluation saves time compared with workshops and spreadsheets because all jobs are evaluated using the same framework. It improves objectivity and comparability and provides a transparent record of every evaluation step. This makes coordination with the works council and management easier and creates evidence for decisions later on.

43. How does easygrading.de support salary analysis?

easygrading.de analyses current salaries based on job evaluation. Actual salaries can be imported and compared across jobs, including variable pay components. Results are displayed in charts, and a gender analysis shows differences within each grade. Pay is compared with the value of the job rather than the performance of the individual. The Basis version includes job evaluation, your own organisational structure and cross-comparison; variable pay analysis, charts and gender analysis are reserved for Pro.

44. Can salary bands be created with easygrading.de?

Yes. easygrading.de helps define and display salary bands for each grade. This provides consistent ranges for job advertisements, employee information requests and comparisons with actual salaries, increasing transparency and comparability.

45. How does the tool help address the gender pay gap?

easygrading.de makes pay differences within each grade visible: its gender analysis compares the salaries of women and men in jobs of equal value, allowing unusual patterns to be investigated. The company must determine whether a difference is justified. The software does not guarantee discrimination-free pay, but provides the data needed to identify and address its causes.

46. How can easygrading.de help with reporting?

easygrading.de provides gender pay gap analysis for each grade, supplying essential data for reports and joint pay assessments. The software helps calculate the data; preparing and submitting the statutory report remains the company's responsibility.

47. Is the application suitable for companies of all sizes?

easygrading.de is primarily aimed at companies with at least 100 employees. They will have to address the directive in the coming years: reporting under Article 9 is staggered by size. Employers with at least 250 employees report annually from 2027, those with 150 to 249 every three years from 2027, and those with 100 to 149 every three years from 2031. This requires a transparent evaluation of their jobs. It is particularly relevant where no systematic job evaluation exists, for example for jobs outside collective agreements or without collective bargaining coverage.

Smaller companies can also make good use of easygrading.de. Requirements such as pay information before recruitment and employees' right to information apply to all employers regardless of size. A well-founded job evaluation provides a reliable basis for this.

48. How quickly can companies get started with easygrading.de?

You can start immediately after registration. The trial is free for 30 days. A short onboarding session is free, and formal onboarding is not required. Companies that want additional guidance can book the implementation package.

49. Is the application intuitive to use?

Yes. The interface is designed for a quick start, and the process (answer questions, evaluate jobs, adjust salaries) is explained in three steps. Free online guides are also available.

50. How is sensitive data protected at easygrading.de?

easygrading.de is a web application hosted in Germany (ALL-INKL), and a data processing agreement is available. No personal data is required for job evaluation. Salary and gender information is needed for salary analysis and gender analysis. Depending on how it is processed, this information may be personal data and therefore subject to the GDPR.

51. Can several people in a company use easygrading.de?

Yes. Several people can work with easygrading.de, for example HR managers, line managers and an evaluation panel. Basis includes one user; Pro includes five users.

52. Can it be integrated with existing HR systems?

easygrading.de is deliberately a standalone web application without interfaces to existing HR systems. This has advantages: no IT project or local installation is needed, and salary data is supplied through targeted file uploads rather than transferred automatically from the HR system.

53. How can the easygrading.de method be used in employer communications?

easygrading.de combines two things that work well in employer communications: a proven method and the requirements of the EU Pay Transparency Directive. Its evaluation logic builds on the Paterson Method (Decision Band Method), an analytical job evaluation approach used for decades. The five criteria and grade levels are mapped to the four dimensions in Article 4(4) of the directive (skills, effort, responsibility and working conditions). The result is a transparent, documented evaluation system employers can rely on when communicating with employees, applicants and the works council.

54. How does using easygrading.de affect employer branding?

Transparent job evaluation and salary bands can support an employer's reputation for fairness, for example through salary ranges in job advertisements and clear responses to information requests. However, employer branding only benefits when practice matches the message. A slogan alone cannot replace transparency in everyday work.

55. What is the job evaluation process in easygrading.de?

First, the company sets up its organisation and answers questions about data, salaries and positions. Each job is then evaluated against the five criteria, typically by an evaluation panel, and easygrading.de assigns it to one of 28 grade levels; role-specific working conditions are added through the supplementary module. Salary bands can then be created, actual salaries analysed across jobs, and the results documented.

56. Can individual adjustments be made?

Individual adjustments are not possible in the definitions section, which contains the standard definitions of criteria and levels. This ensures consistent, comparable evaluations. Company-specific requirements can be stored in the supplementary company section, allowing the standard definitions to be extended flexibly.

57. Is there a trial version?

Yes. The trial is free for 30 days and does not need to be cancelled. It is a demo account: you can carry out up to 10 job evaluations, cannot use your own salary data, and salary analyses use a sample company. This lets you explore the process without risk.

58. Are the evaluation criteria documented?

Yes. easygrading.de documents every evaluation step and criterion for each job. This allows you to demonstrate to employees, the works council and in disputes why a job is assigned to its grade level.

59. How can I introduce easygrading.de in my company?

Implementation is straightforward: you can start directly after registration, a short onboarding session is free, and formal onboarding is not required. Three steps are helpful: involve the works council and evaluation panel early, evaluate jobs and derive salary bands, then review current salaries and plan adjustments. Companies that want guidance can book the implementation package (five days of advisory support, plus a Pro licence).

60. Where can I find more information about easygrading.de?

Further information and support are available directly at easygrading.de and respondeo.de. Free online guides are also available on easygrading.de.

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