With the EU Pay Transparency Directive (“EUPTD”) due to be brought into force by EU Member States by 7 June, the European Union has finally published revised guidance for employers to help prepare for the Directive.

The European Institute of Gender Equality (EIGE) has released an updated toolkit to help organisations across the EU implement gender-neutral job evaluations and classification. This resource will be particularly valuable for employers working towards compliance with the EU Pay Transparency Directive (EUPTD) and looking to strengthen their total reward strategies.

Why Are These Guidelines Important for Your Organisation?

Adopting an objective and gender-neutral job classification is needed to able to categorise workers performing work of equal value, for the purposes of the EU Pay Transparency Directive and beyond. It’s a key step towards:

• Ensuring equal pay for work of equal value between women and men
• Building trust and transparency in pay systems
• Attracting and retaining talent in a competitive market by linking clear career paths
• Reducing legal risks and ensuring compliance with EUPTD and other pay transparency requirements

What Is a Gender-Neutral Job Classification?

This approach provides a fair and objective way to compare jobs and assess their relative value, making use of clear, objective, and bias-free criteria. This forms the foundation for robust and equitable pay structures. By focusing on the requirements of the role rather than the individual, organisations can ensure all job demands are recognised. Also, soft skills, often more present in jobs which were traditionally female-dominated, should be sufficiently considered. 

How the Toolkit Supports EUPTD Compliance

EUPTD introduces stringent requirements for pay transparency and reporting, including the obligation to establish a categorization based on non-discriminatory and objective gender-neutral criteria when defining equal work or work of equal value. This toolkit directly addresses these requirements by providing a structured framework with factors and subfactors for assessing and comparing jobs across all the mandatory criteria as set out in the EUPTD. This includes an extensive user guide with definitions and comprehensive guidance as well as an Excel tool, enabling calculations. This not only helps organisations meet their legal obligations but also provides clear documentation and evidence to support compliance in the event of audits or employee queries.

Who Can Benefit?

The toolkit is designed for all employers, from micro-organisations to large enterprises. It supports those implementing job evaluation and classification for the first time, as well as organisations seeking to stress-test or enhance existing systems. With three tailored approaches, the toolkit makes it practical for every organisation to implement a gender-neutral job classification.

Key Features of the Toolkit

1. Factor and Subfactor Plan 

The toolkit uses the four main factors for job evaluation aligned with EUPTD obligations, applicable across all sectors and organisation sizes. These factors are additionally broken down into subfactors:

1. Skills: Knowledge; Interpersonal and communication skills; Problem-solving skills; Planning and organisational skills; Physical skills
2. Responsibility: People; Goods and equipment; Information; Financial resources
3. Effort: Mental effort; Psychosocial and emotional effort; Physical effort
4. Working conditions: Environment (physical, psychological or emotional); Organisational environment 

The subfactors provide a further detailed and objective framework for describing and evaluating jobs. Subfactors are effective when tailored to sector needs, consistently structured, and free from gender bias. In line with the directive, the factor plan also explicitly integrates soft skills that are often overlooked when evaluating traditionally female-dominated jobs but are essential for achieving equal pay for work of equal value.

2. Practical Supporting Materials 

To support implementation, the toolkit provides additional material including:

• Excel worksheets for job evaluation
• Ready-to-use questionnaires
• Interview guides
• Job profile templates
• A plain language glossary

The Application in Practice 

In practice, we find that many employers are applying their existing job architecture or levelling/grading system rather than implementing a whole new job evaluation system. In some countries (e.g. Italy), the draft implementing legislation for the EU PTD states that employers can use the classification system set out in an applicable Collective Bargaining Agreement, instead, provided that it is not shown to be discriminatory. We recommend mapping your current system against the predefined criteria in the guidance to validate its adequacy and identify any gaps.

However, even with a robust toolkit in place, organizations often still encounter significant complexity in the application of the system, navigating stakeholder management, securing worker representatives' validation, and executing effective employee communication strategies. These interconnected dimensions require a careful approach. Engaging expert support during design and implementation can substantially improve outcomes and ensure compliance is achieved efficiently and sustainably.

In summary, the updated EIGE guidelines offer a practical, robust best practice framework for achieving compliance and advancing workforce fairness. By leveraging these tools, and expert support where needed, you can ensure your organisation is well-positioned for upcoming regulations and a future-proof framework. Even if you are not adopting a new job evaluation system, you may want to take heed of the guidance provided when assessing whether your own job architecture is fit for purpose under the EU PTD.

Your contacts

At Deloitte, we understand that navigating the demands and complexities of pay equity and transparency can be daunting. Our proposition is designed to help you overcome this challenge and achieve your goals. Our aim is to enable you to pay employees equitably and help you demonstrate that you are doing so.

With our deep multi-disciplinary expertise in reward, employment law, technology & analytics, and behaviour change, we are well-placed to be your trusted partner on this journey. Get in touch to discuss your challenges and needs.

Kathryn Dooks, Partner, Deloitte Legal, 020 7303 2894

Deepinder Lamba, Partner, Deloitte Global Employer Services, 020 7007 2689

* The information provided is for general informational purposes only and may not be complete or up-to-date. Do not rely on this information without seeking professional advice. Deloitte LLP accepts no liability for any loss occasioned by any person acting or refraining from action as a result of this content.