Pay transparency · EU 2023/970

Pay transparency.
From the HR system, not from spreadsheets.

Salary ranges in job ads, job categories, pay and benefit data, information requests with a two-month deadline and a gender pay gap report — where your employee data already lives.

Where does regulation stand?

  • The directive

    EU 2023/970. Member states had to transpose it by 7 June 2026.

  • Reporting

    Under the directive: above 250 employees yearly, first in 2027 (for 2026); 150–249 every three years from 2027; 100–149 every three years from 2031.

  • Regardless of size

    Telling applicants the starting pay or its range, and employees’ right to request information, apply to every employer under the directive.

  • Joint pay assessment

    If a category shows a gap of 5% or more that objective criteria do not explain, and it is not remedied within six months.

  • National law

    The national transposition sets the report format and the details. That is why the threshold, the smallest reportable group and the response deadline are configurable.

This page is not legal advice. Status: November 2026.

Requirement → screen

What the directive asks for, and where it lives in the system.

Eight obligations, each with its place — not in a separate spreadsheet, but in recruiting, in documents and next to employee data.

  • Art. 5

    Pay range for applicants

    The position’s salary range appears in the job ad and on the careers page. You can require a range before an ad can be published.

    Recruiting
  • Art. 5

    No questions about previous pay

    The application form asks for salary expectations, never previous pay.

    Recruiting
  • Art. 4

    Work of equal value

    Job categories based on four criteria, with a score and a suggested category. HR decides; any deviation from the suggestion is logged with a reason.

    Job categories
  • Art. 6

    Pay criteria for employees

    The “pay and progression policy” template follows the directive’s structure. Roll it out, collect acceptance, and see who has not accepted yet.

    oneDox
  • Art. 7

    Information within two months

    The employee requests it with one button; HR sees the deadline. The answer shows their own pay and the category’s average and median by gender.

    Pay and benefits
  • Art. 7

    Yearly reminder of the right

    A yearly notice on the home screen and by email; delivery is logged.

    HR Outbox
  • Art. 9

    Pay gap report

    Mean and median; base pay, variable pay and benefits separately; share of recipients, quartiles, per category. The final version as PDF.

    Pay gap report
  • Art. 10

    Joint pay assessment

    A gap of 5% or more without a reason turns red. One click opens a case: review, consultation with employee representatives, action plan with owner and deadline.

    Pay gap report
Pay gap report

You see where the gap is, and what causes it.

Mean and median by gender; base pay, variable pay and benefits separately, per category. Where the gap reaches 5% and no objective reason is recorded, the row turns red.

Above 5% with no recorded reason: a red row — one click opens a case.

Pay gap report: indicators (mean, median, base, variable, benefits) and the per-category table with two rows awaiting a reason
Sample data, test environment. Small groups show “n. k.” — not reportable.
Threshold5% Smallest group3 Response deadline60 days

All three are configurable. While data is missing (base pay, gender, category), the report is “preliminary” and lists whose data is missing.

Pay is more than base pay.

The report works with total remuneration. Every item has a validity date, annualised and scaled to full time.

  • Base pay

    Monthly gross with working-time ratio. This is what the system compares with the category’s salary range.

  • Variable pay

    Bonus, commission, shift allowance and other regular allowances.

  • Benefits in kind

    Cafeteria, meal and leisure cards, private use of company car and phone, language course, housing support, insurance — with unit prices.

  • Import

    From your payroll export (xlsx, csv). Columns map by header; the preview shows what is new and what changes.

An employee’s Pay tab: salary range, base pay, variable pay, benefits and yearly total, each component with its source
The employee’s Pay tab — visible only with pay rights; every view is logged.

When an employee asks, the answer is ready.

Information requests must be answered within two months. The system calculates what goes into the answer; HR checks and sends it.

  1. Request

    The employee requests it with one button on their own Pay tab. HR records requests made verbally or on paper on their behalf.

  2. Deadline

    The request list shows the time left; HR Now flags it 10 days before and at the deadline.

  3. Answer

    Their own pay and the job category’s average and median by gender. For groups smaller than three: “not reportable due to group size” instead of a number.

  4. Send

    A PDF goes into the employee’s documents and by email. The answer is logged as a pay view.

Composing the answer: the employee’s pay level and the groups doing work of equal value; small groups are not reportable
Sample data. The group average excludes the requester’s own pay.

What counts as work of equal value?

The system suggests, HR decides. The category carries the salary range, so the job ad, the employee and the report look at the same range.

  • Evaluation

    Four criteria (skills, effort, responsibility, working conditions) from 1 to 5. Criteria, scale and weights can be tailored to the company.

  • Suggestion

    The score falls into a category’s point range — that is the suggestion. A deviation needs a reason; every change is logged.

  • Salary range

    If a position’s range falls outside its category’s, recruiting warns. If an employee’s base pay falls outside, it can be tracked as a case with owner and deadline.

  • Haver

    If enabled, it suggests scores from the job description, with a reason per criterion. HR decides.

Job categories K1–K5: point range, gross monthly salary range and number of assigned jobs
A starter set with five categories — editable.

Who sees pay data?

  • Separate rights for viewing and for recording.
  • Every view is logged; the employee’s Pay tab shows who looked.
  • Employees see their own pay.
  • Neither the answer nor the report shows another employee’s individual pay.
  • The module is switched on separately; it is off by default.

Deliberately not included

  • Payroll and cafeteria payouts — the data comes from there; this does not replace them.
  • A job evaluation methodology — the company sets the criteria.
  • Market pay benchmarking.
  • Legal advice — the system is a compliance tool; decisions stay with the employer.

Where to start now?

Under the directive, companies above 250 employees report first in 2027, covering 2026. The data has to be in order by then.

  1. Classify jobs

    Categories and point ranges; the starter set has five categories.

  2. Salary ranges

    For categories and open positions — job ads take it from here.

  3. Pay and benefit data

    Import from payroll, and gender on the HR record.

  4. Policy

    Roll out the pay and progression policy and collect acceptance.

  5. Trial report

    Where data is still missing, and where a gap above 5% has no objective reason yet.

Frequently asked questions

When do we have to report the gender pay gap?

Under the directive, employers with more than 250 employees report yearly, first in 2027 (for 2026); those with 150–249 every three years, also from 2027; those with 100–149 every three years from 2031. The exact national rules come from the national transposition.

Does the system make us compliant?

The system is a compliance tool: it collects the data, calculates the indicators, watches the deadlines and keeps a log. Compliance comes from the employer’s decisions — classification, reasons, answers. It does not give legal advice.

Do we need new payroll software?

No. Pay and benefit data can be loaded from your existing payroll export (xlsx or csv). Columns map by header, so the next export fits too.

What counts as pay?

Base pay, variable pay (bonus, commission, allowances) and benefits in kind (such as cafeteria, company car, phone) — annualised and scaled to full time. The report also shows all three separately.

What if a group is too small?

If fewer than three employees of one gender are in a group, “not reportable” appears instead of a number, both in the answer and in the report. The threshold is configurable.

Does AI help?

If Haver is enabled, it suggests scores from the job description, and summarises from the report’s aggregate figures what may cause the gap. No individual pay goes to the model; HR decides.

Can it be added to an existing system?

Yes. Pay transparency is a separate module: off by default, and it can be switched on in the existing system, next to the employee data.

Let’s talk about where you stand.

A trial report shows where data is still missing, and which gaps still need a reason.