Checklist: 20 Steps to Compliance
A practical checklist for HR teams: from pay audits and job evaluation to report building and remediation actions. Step-by-step guide to becoming compliant.
Phase 1: Mapping and Inventory (Steps 1–5)
1. Conduct an inventory of all positions and worker categories in the organization. 2. Map existing pay data — base salary, allowances, bonuses, and benefits per employee. 3. Verify that you have an up-to-date job evaluation model that classifies equivalent work. 4. Identify which worker categories should be compared in the pay gap analysis. 5. Ensure your HR system can export data in the format required for reporting.
Phase 2: Analysis and Action Plan (Steps 6–10)
6. Calculate the mean and median pay gap per worker category. 7. Analyze the quartile distribution of women and men in each pay category. 8. Identify worker categories where the pay gap exceeds 5%. 9. Document objective justifications for any pay differences. 10. Establish an action plan with timelines for correcting unjustified pay gaps.
Phase 3: Processes and Policies (Steps 11–15)
11. Update the recruitment process — include salary ranges in all job postings. 12. Remove salary history questions from interview templates and recruitment forms. 13. Create an internal pay transparency policy that meets the directive's requirements. 14. Train managers and HR on the new rules and the reversed burden of proof. 15. Establish procedures for employees to request pay information.
Phase 4: Reporting and Communication (Steps 16–20)
16. Build reports in DO's format with all mandatory key metrics. 17. Conduct joint pay assessments with worker representatives at the 5% threshold. 18. Communicate results internally to employees and unions. 19. Publish the pay gap report externally if you have 250+ employees. 20. Establish an annual cycle for pay audits, reporting, and follow-up.