Pay Gap Reporting: What Data Do You Need?
Understand the requirements of Article 9 — mean and median pay gap, quartile distribution, bonus gap, and reporting by worker category. What data to collect and how often.
What Does Article 9 Require?
Article 9 of the EU Pay Transparency Directive sets detailed requirements for what pay data employers must report. The purpose is to create comparable and transparent data on pay gaps between women and men within each organization.
Mandatory Key Metrics
Employers must report: the mean pay gap between women and men, the median pay gap, the mean gap in complementary or variable components, the median gap in complementary or variable components, the proportion of women and men receiving complementary components, the proportion of women and men in each pay quartile, and the pay gap by category of worker.
What Data Do You Need to Collect?
To calculate these key metrics, you need: base salary per employee, all forms of allowances and bonuses, benefits with economic value, gender per employee, position and worker category, and working hours (full-time/part-time) to calculate full-time equivalents.
Reporting Frequency
The reporting frequency depends on the organization's size: employers with 250+ employees report annually, employers with 100–249 employees report every three years. The first report must be submitted by 20 May 2028. Employers with fewer than 100 employees may report voluntarily.