Pay gap reporting checklist
Pay gap reporting checklist for EU employers: headcount thresholds, worker categories, pay components, 5% gap trigger and evidence.
Direct answer
A pay gap reporting checklist should cover headcount threshold, worker categories, pay components, bonus and variable pay, quartiles, same-work or equal-value groups, objective justification, worker representative process and joint pay assessment triggers where an unexplained gap exceeds 5 percent.
What should be on a pay gap reporting checklist?
A pay gap reporting checklist should cover headcount threshold, worker categories, pay components, bonus and variable pay, quartiles, same-work or equal-value groups, objective justification, worker representative process and joint pay assessment triggers where an unexplained gap exceeds 5 percent.
- Confirm threshold
- Define comparator groups
- Prepare justification file
| First broad report deadline | 2027-06-07 for larger employers |
| Key trigger | Unexplained 5% category-level gap |
| Main evidence | Pay data, grouping method and objective justification |
A pay gap reporting checklist should cover headcount threshold, worker categories, pay components, bonus and variable pay, quartiles, same-work or equal-value groups, objective justification, worker representative process and joint pay assessment triggers where an unexplained gap exceeds 5 percent.
Employers above certain thresholds must begin pay reporting under phased rules.
Source: European Commission equal pay and pay transparency guidance
Pay gap reporting checklist checklist
Action checklistCheck employee headcount and national implementation.
Create objective categories for same work or work of equal value.
Record objective reasons for pay differences and remediation plans.
Key deadlines
| Date | Requirement | Source |
|---|---|---|
| 2027-06-07 | First reports for larger employersEmployers above certain thresholds must begin pay reporting under phased rules. | European Commission equal pay and pay transparency guidance |
30/60/90-day action plan
First 30 days
Confirm scope and assign an owner
Evidence needed: Applicability note, business owner, systems or product list, and source links.
Pay gap reporting
Days 31-60
Close the evidence gaps
Evidence needed: Policies, supplier records, data maps, technical notes, training records, or process owners.
Pay gap reporting
Days 61-90
Prepare for audit or customer review
Evidence needed: Versioned compliance file, action log, exception register, and next review date.
Pay gap reporting
Evidence to retain
Applicability decision
Shows whether pay gap reporting readiness applies and why the SME made that decision.
Retain: Scope memo, trigger criteria, country notes, owner approval, and review date.
Action owner list
Regulators and enterprise customers expect named accountability, not generic intent.
Retain: Owner, backup owner, due date, status, and unresolved blocker notes.
Evidence folder
The fastest way to answer customer due diligence is a single audit-ready evidence file.
Retain: Policies, screenshots, registers, exports, supplier responses, and training records.
SME questions answered
Which employers need pay gap reports?
The directive phases reporting obligations by headcount, starting with larger employers, while national laws may add stricter thresholds.
What happens if a pay gap exceeds 5 percent?
Where an unexplained gap exceeds the directive threshold, a joint pay assessment may be required under the rules.
Turn this guide into a tracked action plan
Start with the Regulation Checker, save the result, and import the action plan into your EuroComply dashboard when you are ready to assign owners.
Informational only. This page is not legal advice and does not replace a qualified legal review of your business, systems, products or employment practices.