Directive guide

Pay gap reporting: the 7 metrics, step by step

In short

Employers with 100+ employees report 7 metrics computed on complete remuneration — mean and median gaps, the variable-component gaps, who receives variable pay, the sex split per pay quartile, and the gap per category of work of equal value. Management confirms the figures, workers’ representatives can interrogate the methodology, and the report goes to the national monitoring body, which publishes it.

1. Who reports, and when

Size	First report	Frequency
250+ employees	by 7 June 2027	annual
150–249 employees	by 7 June 2027	every 3 years
100–149 employees	by 7 June 2031	every 3 years

The report covers the preceding calendar year. Below 100 employees reporting is voluntary unless the member state extended it.

2. The 7 metrics (Art. 9(1) a–g)

the mean gender pay gap
the mean gap in complementary or variable components (bonuses, commissions, benefits)
the median gender pay gap
the median gap in complementary or variable components
the proportion of female and male workers receiving variable components
the proportion of female and male workers in each quartile pay band
the pay gap for each category of workers doing the same work or work of equal value, split into ordinary basic salary and variable components

Metric (g) is the one with teeth

The per-category gap is where the 5% threshold applies, where justification on objective criteria is judged, and what workers’ representatives will look at first. The six aggregate metrics describe the company; metric (g) decides whether you have a legal problem.

3. The mechanics that decide whether your numbers are right

Complete pay, not base salary — variable components and benefits in kind enter the calculation (Art. 3).
Hourly comparability — part-time work must not masquerade as a pay difference: normalise to gross hourly pay / full-time equivalent.
Stable categories — the same job evaluation across years, versioned; changing categories between reports without documentation reads as gap management.
A reproducible method — representatives are entitled to ask how the figures were produced; “the consultant’s spreadsheet” is not an answer. Egalis freezes each report with its parameters and audit trail.

4. After submission

The monitoring body publishes employer-level data, so your gap becomes comparable — candidates, journalists and competitors will read it. Unjustified differences must be remedied in cooperation with workers’ representatives, and a ≥ 5% per-category gap left unjustified and unremedied for 6 months triggers the joint pay assessment. The companies that will look good in 2027 are the ones watching their categories monthly in 2026 — start with the calculator.

Frequently asked questions

Which pay counts in the calculation?

Complete remuneration: ordinary basic salary plus complementary or variable components — bonuses, commissions, overtime, benefits in kind. Reporting basic salary alone understates the gap and does not comply with Art. 3.

Who confirms the figures?

The employer's management confirms the report, after consulting workers' representatives — who are entitled to ask for and receive explanations of the methodology behind the figures.

Where does the report go, and who sees it?

To the national monitoring body (Art. 29), which publishes the employer-level data. Metric (g) — the per-category gap — is shared with workers and their representatives, not published. Public comparability between employers is part of the design.

Can we outsource the report to our accountant?

The arithmetic, perhaps — but the report stands on categories of work of equal value, which require a documented job evaluation, and on choices (FTE normalisation, benefit valuation) that must be consistent and explainable to representatives. That is a system, not a spreadsheet.