EU Pay Transparency Directive: Job evaluation and classification guidelines

Why should I read this?

The deadline for the transposition of the EU Pay Transparency Directive (Directive) into national laws passed on 7 June 2026. While much attention has focused on reporting thresholds and disclosure obligations, gender neutral job evaluation and classification sit at the core of the regime. These mechanisms provide the framework for determining whether work is of equal value, which in turn underpins the pay comparisons required under the Directive.

The European Commission together with the European Institute for Gender Equality have published updated EU-wide guidelines on gender-neutral job evaluation and classification (EU Guidelines). The EU Guidelines take the form of a practical, step-by-step toolkit. It is anticipated that the EU Guidelines will be used both by organisations that are new to job evaluation and classification processes, and those seeking to refine their existing systems. In practice, the EU Guidelines are also likely to act as an informal benchmark for regulators, equality bodies and the courts.

This briefing gives an overview of the EU Guidelines, the potential pitfalls and risk areas and the position on national guidelines, including the guidelines recently published in the Netherlands. It also sets out practical steps that employers should take.

What do I need to know?

The EU Guidelines are not law. They are a voluntary resource that provide recommendations, examples and templates. They are intended to support employers in designing and operating gender‑neutral job evaluation and job classification systems that provide an objective basis for determining if jobs performed by workers are of equal value.

A job evaluation is a systematic process for determining the relative value of two or more jobs, based on objective criteria. The Directive requires that those criteria should include skills, responsibility, effort and working conditions, and any other factors that are relevant to the specific job or position. The emphasis is on the work performed, not the person performing it, and on criteria that can be transparently evidenced and explained.

A job evaluation provides the basis for comparing jobs within an organisation, the outcome of which is a job classification system which can, in turn, form the basis of a pay framework. Employers can still pay workers within each grade differently, on the basis of appropriate factors such as their performance and competency, but this is distinct from an “equal value” assessment. Further, the Directive requires that the process used to determine such pay must also follow criteria that are gender-neutral and free of gender bias. This distinction between role value and individual reward is critical, and is often where legacy pay practices come under the most scrutiny. 

The EU Guidelines were published in March 2026 and are made up of ten practical tools (eight for employers and two for trade unions and workers) designed to support the entire job evaluation process, from preparation and planning through to implementation and ongoing review. Reflecting that there is no single methodology that is uniformly accepted as compliant in determining equal value because the appropriate pay structure and relevance of criteria will depend on the particular organisation, the EU Guidelines set out several suggested evaluation methodologies depending on the size of the employer.

In summary, the EU Guidelines are structured as follows: 

Preparation phase

• Tool 0: assists evaluators in understanding how gender bias impacts job evaluation and in reflecting on their own assumptions about a role, in order to prevent gender bias from entering the process
• Tool 1: provides a step plan for organising a gender-neutral job evaluation, including establishing a job evaluation committee, preparing a project outline, building organisational understanding, and communicating with worker representatives or trade unions
• Tool 2: assists in creating job profiles by gathering information and insights through questionnaires and interviews

Evaluation phase

• Tool 3: is designed for micro-organisations with fewer than 10 workers, using a simplified graduated factor comparison method. Each role is evaluated against a predefined set of factors and levels, with all core criteria and subfactors weighted equally. The points associated with the selected levels are then aggregated to identify categories of workers
• Tool 4: is for small and medium-sized enterprises (10 to 249 employees, with fewer than 15 distinct roles), using a pair comparison method under which every job is compared directly with all others using the core factors and then ranked from the most to least extensive requirements
• Tool 5: is the standard approach, intended for employers with over 50 employees and more than 15 distinct roles. It applies a comprehensive analytical point-factor method with customisable weightings (see further below)

Follow-up phase

• Tool 6: provides a checklist to help employers review job titles and descriptions for gender-biased language
• Tool 7: provides a self-assessment framework for monitoring results, aligning HR policies with job evaluation outcomes, communicating, and planning regular review cycles

Tools for trade unions and workers

• Tool 8: is addressed to trade unions, providing guidance on how unions can advocate for equal pay and overcome any employer resistance
• Tool 9: is designed for individual workers, helping them understand their equal pay rights and their rights under the Directive, including the right to information, and providing guidance on how to initiate pay-related conversations with their employer

A number of supporting resources are also provided, including a detailed factor and subfactor plan suggesting what to assess when evaluating jobs, ready-to-use templates such as a job profile template, a project outline template, a standard job description template, a sample worker questionnaire, interview guides, and Excel worksheets for classifying jobs and checking for gender pay gaps.

Applying the standard approach

The standard approach is the most rigorous of the three evaluation methodologies set out in the EU Guidelines and is intended for use by employers with more than 50 employees and more than 15 distinct roles. Its design reflects the level of sophistication expected of larger organisations, setting out a series of defined stages.

The employer first defines a total points framework representing 100% of the available score. The four core criteria (skills, responsibility, effort, and working conditions) are then each assigned a percentage weighting, and each subfactor within those criteria is further weighted to reflect the organisation's sector, values, and strategic objectives. The EU Guidelines provide a default weighting scheme: 40% is allocated to skills (480 points), 35% to responsibility (420 points), 15% to effort (180 points), and 10% to working conditions (120 points), yielding a maximum total of 1,200 points.

Each job is then evaluated/scored against the selected subfactors by reference to the predefined level descriptors. The evaluator assigns a level to each subfactor for the role in question, and the corresponding points are aggregated to produce a total score for that role. The methodology is designed to make evaluative judgment explicit and traceable.

For the purpose of identifying comparable categories of workers, it is recommended that each 10% band of the total score constitutes a separate worker category. For example, under the default 1,200-point framework, roles scoring between 0 and 120 would fall into one category, those scoring between 121 and 240 into the next, and so on.

Once the assessment is completed, the resulting scores should be used to create or adjust the employer's pay structure by grouping jobs with similar scores into pay grades and applying pay ranges for those groups.

National guidelines

In accordance with the Directive, Member States are required to make analytical tools or methodologies available to support employers. Very few have yet done so, and now that the EU Guidelines have been published, it is possible that many Member States will rely simply upon or formally reference the EU Guidelines rather than develop bespoke national tools or methodologies of their own.

The Netherlands is one of the few jurisdictions that has published national guidelines. The Dutch research institute (Verwey-Jonker), commissioned by the Dutch government, recently developed and published a handbook. In summary, the handbook identifies three routes for employers to carry out job evaluation:

• Route A — Outsourced evaluation: The employer uses a recognised job evaluation system provider. The method must rely on gender-neutral and objective criteria, job descriptions must be up to date, and the process must be documented and verifiable
• Route B — Sectoral reference jobs: Employers use reference jobs from a collective labour agreement (CBA) or sector organisation, translate them into the mandatory criteria, and document whether, and if so, why each internal job matches the selected reference job
• Route C — Own analytical system: The employer sets up its own point-based job evaluation system. This involves forming an evaluation committee, mapping job content, assigning scores per criterion, weighting the criteria, and applying corrective measures where gender bias is detected

The handbook makes clear that following the job evaluation guide in the handbook does not on its own provide a legal defence to claims of pay discrimination or non-compliance with the Directive. However, applying its principles will help employers demonstrate compliance, and may help an employer to discharge the burden of proof in the event of equal pay claims.

In practice, employers will need to have regard to both the EU Guidelines and any national analytical tools or guidance that emerge, not only to ensure technical compliance but to understand how individual authorities intend to structure enforcement and assess evidence in practice.

Potential pitfalls and risk areas

Notwithstanding the structured nature of the EU Guidelines and local analytical tools or guidance, there remain potential pitfalls for employers.

In particular, where guidelines or methodologies allow for deviations, there is scope for direct or indirect gender bias to creep in. For example, employers may adjust the weightings when applying the standard approach under the EU Guidelines, and will need to be careful in that respect not to do so in a way that disadvantages female-dominated roles. It will therefore be important that any deviations from the default are objectively justified and documented.

Although the EU Guidelines and national guidelines seen to date do not amount to legislation, they are likely to be practically persuasive. In particular, as highlighted above, employers should anticipate that equality bodies and labour inspectorates will refer to them when setting enforcement expectations, and assessing compliance in practice. For example, such bodies may expect medium and large employers to adopt analytical systems in accordance with the EU Guidelines, rather than simplified ones. Employers should therefore monitor any guidelines being issued by national authorities and how each relevant jurisdiction engages with the EU Guidelines.

Any gold-plating of the Directive’s requirements in national guidelines should also be monitored. For example, the EU Guidelines envision a more active involvement of worker representatives throughout the job evaluation process than is required under the Directive alone, which may result in trade unions and works councils seeking greater involvement in job evaluation and pay structuring exercises. In particular, the EU Guidelines suggest that employers include a representative from a relevant trade union or works council on the job evaluation committee, involve representatives before the job evaluation starts, allow trade union representatives to be a partner in the design, application and periodic review of the job evaluation and classification system, and invite representatives to take part in the comparison exercise once draft results are available.

The EU Guidelines state that collective agreements may need to be revised, or the organisation may need to go beyond the minimum requirements set down in the collective agreement, in order to ensure that there is full compliance with the principle of equal pay. It should not therefore be assumed that the existence of a collective agreement governing pay, grading or job classification will, of itself, absolve an organisation from ensuring that its job evaluation and classification processes are genuinely gender‑neutral.

Where a job evaluation identifies that certain roles have been undervalued, the EU Guidelines make clear that the appropriate response to address that should not be by reducing the pay of comparator roles. Reducing pay to achieve alignment would risk breaching contractual protections, undermining employee trust, and exposing employers to additional legal and employee‑relations risk, while failing to address the underlying inequality. Corrective measures should therefore focus on upward adjustment, supported by clear documentation of the evaluation outcomes and the rationale for any changes.

What should employers do now?

As is highlighted by the detailed nature of the EU Guidelines, establishing new job evaluation and classification processes and refining existing systems requires careful and detailed planning and resource.

• Assess existing frameworks: Pay reporting, disclosure rights and equal pay claims will stand or fall on the robustness of the underlying job evaluation framework. Employers should therefore carefully assess whether their existing job evaluation or grading systems align with the analytical principles reflected in the EU Guidelines and any local standards, particularly for medium and large workforces
• Put governance and documentation in place: The EU Guidelines place significant emphasis on process, transparency and traceability. Employers should establish clear governance structures, define roles and decision‑making authority, and ensure that evaluation outcomes and deviations are consistently documented. This will be critical in discharging the burden of proof in any future challenge
• Stress‑test discretion and weighting decisions: Where employers tailor criteria, weightings or subfactors to reflect their business model or sector, they should interrogate whether those choices could disadvantage female‑dominated roles. Any deviation from default approaches should be objectively justified, evidence‑based and capable of explanation to regulators, worker representatives and in litigation
• Engage proactively with worker representatives: Even where national law does not mandate extensive involvement, the EU Guidelines signal an expectation of meaningful engagement with social partners. Employers should plan how and when to involve trade unions or works councils in a way that is structured, proportionate and aligned with local legal requirements
• Monitor national guidance and enforcement signals: As Member States publish analytical tools and guidance, employers should track how closely national authorities align with the EU Guidelines. Early awareness will allow organisations to adjust approach before enforcement expectations crystallise

Resources and how we can help

The EU Guidelines are available at EU-wide guidelines on gender-neutral job evaluation and classification: Step-by-step toolkit | European Institute for Gender Equality.

With our established equal pay practice, we are ideally placed to support employers with pay transparency compliance, including:

• advising on how to structure the project to maximise privilege and the confidentiality of sensitive pay data and potential gaps
• reviewing pay architecture through the lens of work of equal value to ensure compliance with the Directive
• conducting pay gap analyses against current practices
• advising on local legal developments
• developing action plans
• drafting EU consistent templates and processes
• delivering training

You can track the latest developments on our Navigating Global Pay interactive site, as well as accessing essential FAQs, timelines, a summary of the Directive, a glossary and briefings (request access to our site here). With the added benefit of our Diversidata product which provides the latest information around the collection, retention and use of diversity data, our teams are ideally placed to help companies ensure legal compliance.