Pay Transparency Compliance Checklist

Owned by the pay transparency lead. Enter the cycle start date on the first task: every due date counts forward from it in working days. Choose where you employ or hire people and whether an EU pay gap report is due this cycle, and the tasks for those places appear.

• Set up the cycle: your organisation, where you employ people, the start date and the people — your organisation, the EU countries and US states or cities where you employ or hire people, whether an EU pay gap report is due this cycle, the start date and the people who run each part; later tasks are assigned from these fields and every due date counts from the start date
• Count the workers each employer has in each country and state — the number of workers each employing entity has in each EU country and each US state, and the date you counted, because the report thresholds and the state posting rules depend on headcount
• Agree the timetable and how workers’ representatives take part — the dates for each phase, who owns each part and, where you have workers’ representatives, how they take part in the job evaluation criteria, the report and any joint pay assessment

Check the law for every place in the first task before you change anything. EU countries had until 7 June 2026 to bring the Directive into their own law, and on 9 November 2026 EUR-Lex listed no measures from ten of them. US states and cities each have their own rules.

• Check how each EU country has brought the Directive into its law — for each EU country in the first task, the national law that brings in the Directive, whether it is in force, and its own thresholds, dates, reporting authority and penalties
• List the pay transparency law for each US state and city where you hire — for each state and city in the first task, whether its law covers you at your headcount and what it requires: pay ranges in postings, a ban on asking about pay history, pay information on request, internal opportunities and records
• Decide what to do in a country whose law is not yet in force — where a country’s law is still a bill or not yet published, what you will prepare now, who is watching for the final text and when you will check again
• Check postings for remote roles that someone in a covered state could fill — remote and hybrid roles advertised to people who could work from a state with a posting law, and which state rules you will follow for them
• Record which duties apply this cycle and the sources — a short list, by country or state, of the duties that apply to you this cycle, with a link to each source and the date you read it; the later tasks follow this list

Group jobs into categories of workers doing the same work or work of equal value, set a range for every job and write down how pay is set. Ranges in adverts, answers to pay requests and the report all come from this phase.

• Group jobs into categories of workers doing the same work or work of equal value — every job in each employer, grouped so that jobs of equal value sit together, judged on skills, effort, responsibility and working conditions; the report’s category figures and any joint pay assessment use these groups
• Check the job evaluation method is gender-neutral — the method used to compare the value of jobs, checked so that no criterion is based directly or indirectly on sex and relevant soft skills are not undervalued
• Set or confirm a pay range for every job — a range for every job, from the lowest to the highest pay you expect to offer, based on objective, gender-neutral criteria; job adverts and answers to pay requests use these ranges
• Write down how pay, pay levels and pay progression are set — the objective, gender-neutral criteria used to decide each worker’s pay, pay level and pay progression, in a form you can share with workers
• List the variable and complementary pay in each category — bonuses, commissions, allowances, benefits in kind and any other pay on top of basic pay, by category, because the report and several US posting laws ask about them
• Check the pay and job data for every worker — each worker’s employer, country, category, sex as recorded, basic pay and variable pay, with gaps and errors fixed before any figures are worked out

Make sure people can get the pay information the law gives them, can talk about pay and are not asked about past pay. These rights run all year, so they are checked before the sign-off rather than after it.

• Check workers can ask for pay information and get it in writing within two months — a way for workers, or their representatives, to ask for their own pay level and the average pay levels by sex for their category, a log of requests, and replies in writing within two months
• Check people can get the pay range on request where state law gives that right — who can ask for a pay range in each state and how you answer, for example applicants and current employees in California, and employees offered a transfer or promotion in Washington
• Remove terms and policies that stop people discussing pay — contract templates, offer letters, handbooks and policies checked for any term that stops workers disclosing or discussing their pay, and changed where the law requires
• Remove pay history questions from forms, scripts and interviews — application forms, screening scripts, agency briefs and interview guides checked so that no one asks about current or past pay
• Decide how answers protect the pay of an identifiable worker — where an answer to a request, the report or a joint pay assessment would reveal the pay of one identifiable worker, how you will handle it under each country’s law

Applies only when an EU pay gap report is due this cycle. Work out the figures for the previous calendar year, look for differences of 5% or more in any category and consult workers’ representatives before the sign-off.

• Confirm who reports, for which year and to which authority — each employer that must report under its national law, the calendar year the figures cover, the authority that receives them and its deadline
• Work out the report figures for the previous calendar year — the seven figures the Directive lists, for each employer that reports, using the categories from Phase 3
• Look for any difference of 5% or more in a category, and its reasons — each category where average pay for women and men differs by 5% or more, and whether objective, gender-neutral criteria justify the difference
• Consult workers’ representatives on the figures and the methods — the figures and the methods shared with workers’ representatives, and their comments recorded and answered, before management confirms the figures

One person signs off the ranges, criteria, notices and any report figures before they are used. The checklist halts at the sign-off: nothing after it can be completed until it is done.

• Prepare the sign-off pack — the pay ranges, the pay-setting and progression criteria, the advert and notice wording, the way requests are handled and, on a report run, the figures and the representatives’ comments
• Put right what the sign-off turned down, then ask again — the changes the approver asked for, made and sent back; the approver then changes the decision to Approved and completes the sign-off
• Sign off the ranges, criteria, notices and any report figures — the approver’s decision that the ranges, criteria and wording can be used and, on a report run, that the figures are accurate after consulting workers’ representatives

Put the approved ranges into every advert and brief everyone who recruits. Until the new ranges are approved, keep the current ones in every advert: the duty applies all year.

• Give applicants the starting pay or its range — the initial pay or its range for each role, and any collective agreement terms that apply to it, in the job advert, before the interview or otherwise, so they can negotiate on pay
• Put the pay range in every job posting where state law requires it — the approved range in every internal and external posting in each covered state, with benefits, other pay and how to apply where the state requires them
• Give agencies and job boards the range for every role they advertise — each agency, job board and recruiter that advertises for you, given the approved range and asked to show it
• Check job adverts and job titles are gender-neutral — advert templates, job titles and the recruitment process checked for wording or steps that could undermine equal pay
• Post internal opportunities, promotions and transfers as state law requires — how internal vacancies, promotions and transfers are announced and what each announcement must include, state by state
• Brief managers and recruiters on the rules — what they may and may not ask, where the ranges come from, how to answer a question about pay and where to send a request for pay information

Applies only when the route includes the EU. Share the pay criteria, send the yearly notice of the right to pay information and, on a report run, submit the figures and give each category’s figures to workers.

• Make the pay-setting and progression criteria easy for workers to find — the approved criteria published where every worker can reach them, in an accessible format
• Tell every worker of their right to pay information and how to ask — a notice to all workers of their right to ask for pay information and the steps to take, sent once a year
• Submit the report figures to the national authority — the figures sent to the authority your national law names, by its deadline, with the confirmation kept
• Give each category’s figures to all workers and their representatives — the gap by category of workers, figure (g), given to every worker and to workers’ representatives
• Decide whether to publish the figures on your website — a decision on whether to publish figures (a) to (f) yourself, and where

Keep the records each law asks for. On a report run, check six months after submitting that every difference of 5% or more is justified or put right; if not, a joint pay assessment with workers’ representatives follows.

• Keep the records each law requires — the ranges, adverts, requests and answers, notices, report figures and methods, kept for as long as each law requires
• Six months after submitting, check each difference of 5% or more — every difference of 5% or more in a category, checked to see whether it has been justified on objective, gender-neutral criteria or put right within six months of submitting the report
• Carry out the joint pay assessment with workers’ representatives — the assessment, carried out with workers’ representatives, covering for each category the share of women and men, average and variable pay, the differences and their reasons, pay improvements after leave, the measures and how earlier measures worked
• Agree the measures and put right the unjustified differences — the measures agreed with workers’ representatives to put right each unjustified difference, with owners and dates, including a review of the job evaluation and classification systems
• Give the assessment to workers, their representatives and the monitoring body — the joint pay assessment made available to workers and their representatives and sent to the monitoring body your national law names
• Review the cycle and set the next start date — what worked, what to change, changes in the law to watch and the start date for next year’s cycle