Pay gap analysis that holds up.
A gender pay gap analysis compares what women and men in your organisation are paid, across the whole workforce and within each category of workers. The EU Pay Transparency Directive (2023/970) makes it a recurring legal duty: employers with 100 or more workers report seven pay gap indicators, and must act on any unjustified gap of 5% or more. As pay gap reporting software built for the EU Pay Transparency Directive, we produce the analysis from a CSV export of your HR system, on a documented methodology, so the numbers you report are numbers you can explain to auditors and workers’ representatives.
- Article 9 indicators, computed from one dataset
- 7
- Article 9 indicators, computed from one dataset
- Gap that can trigger a joint pay assessment
- 5%
- Gap that can trigger a joint pay assessment
- EIGE factors behind every role’s grade
- 4
- EIGE factors behind every role’s grade
What the Directive asks you to measure.
Article 9(1) lists seven indicators. We compute all seven from the same dataset, so the figures agree with each other and trace back to the same people and pay records.
- (a)
the gender pay gap
- (b)
the gender pay gap in complementary or variable components
- (c)
the median gender pay gap
- (d)
the median gender pay gap in complementary or variable components
- (e)
the proportion of female and male workers receiving complementary or variable components
- (f)
the proportion of female and male workers in each quartile pay band
- (g)
the gender pay gap between workers by categories of workers, broken down by ordinary basic wage or salary and complementary or variable components
Source: Directive (EU) 2023/970, Article 9(1). “Pay” means the full remuneration package: basic salary plus every complementary or variable component, in cash or in kind.
Who reports, and when.
Each report covers the previous calendar year. The first deadline is 7 June 2027.
| Employer size | First report due | Then |
|---|---|---|
| 250 workers or more | 7 June 2027 | Every year |
| 150 to 249 workers | 7 June 2027 | Every three years |
| 100 to 149 workers | 7 June 2031 | Every three years |
| Fewer than 100 workers | Voluntary | Unless national law requires it |
Article 9(2) to 9(5).
Mean, median, adjusted and unadjusted.
The Directive defines the gender pay gap as the difference between the average pay of women and men, expressed as a percentage of men’s average pay. The median gap does the same with the middle value of each group, so a few very high salaries move it far less. You report both.
The unadjusted gap is the raw difference, and it is what Article 9 asks you to report. The adjusted gap is what remains after documented, gender-neutral reasons for pay differences within the same grade are taken into account, such as a performance rating HR has attested to, or a market premium backed by evidence. An adjusted gap close to zero means those reasons explain the difference. A large one means they don’t.
The categories of workers are grades. Each role’s grade comes from job evaluation, so people in the same grade do work of equal value under the methodology. See how each factor is defined.
A worked example
Five women and five men, fictional monthly salaries.
| Group | Monthly salaries | Mean | Median |
|---|---|---|---|
| Women | €2,800, €3,000, €3,200, €3,400, €3,600 | €3,200 | €3,200 |
| Men | €2,900, €3,100, €3,300, €3,500, €7,200 | €4,000 | €3,300 |
| Gap | 20.0% | 3.0% |
One salary of €7,200 pulls the men’s mean up, so the mean gap is 20.0% while the median gap is only 3.0%. Neither figure is wrong; each shows something the other hides. That is why the Directive asks for both.
When the gap is 5% or more.
Article 10 requires a joint pay assessment with your workers’ representatives when three things are true at once: your report shows a difference in average pay between women and men of at least 5% in a category of workers; you have not justified it on objective, gender-neutral criteria; and you have not remedied it within six months of submitting the report.
So a gap of 5% is not a fine. It is the start of a question you have to answer, with evidence. Here is what we give you to answer it.
- Every grade is labelled by its gap: within tolerance below 5%, borderline from 5% to 10%, and exceeds threshold at 10% and above.
- Where roles in the same grade are paid 5% or more apart, HR records whether the difference is justified or corrected, with a note. The decision carries forward to the next run.
- When a grade’s adjusted gap is 5% or more, we prepare a joint pay assessment starter pack: the grades concerned, a draft analysis of causes, and an action plan for HR to complete with owners and deadlines.
- HR reviews and approves every section of the pack before it is generated.
Work of equal value, not job titles.
Article 4 requires pay structures that let you compare the value of different jobs on objective, gender-neutral criteria, including skills, effort, responsibility and working conditions. Job titles cannot do this. Two different titles can describe work of equal value, and one title can cover very different work.
We evaluate each role on the four factors of the European Institute for Gender Equality’s framework, split into fourteen subfactors. HR answers a structured questionnaire for each role, and rules turn the answers into subfactor levels, each with a written reason. AI may suggest raising a level, and only by quoting the answer that supports it. HR confirms every result.
The total score sets the role’s grade, and the grade is what the pay gap analysis compares. The weights are configuration, versioned with the methodology, not hidden in the code.
From export to report in three steps.
- 01
Import an export
Upload a CSV export from your HR system. We match the columns; you confirm the mapping and review every change before anything is imported.
- 02
Evaluate roles
Answer the questionnaire for each role. Every role gets a grade from its total score, with the reasoning written down next to it.
- 03
Run the analysis and report
Run the analysis, review the flagged grades, and generate the Article 9 report as a PDF. Its cover records the methodology version and a hash of the dataset, so anyone can check which data produced which numbers.
Pay gap analysis in Excel vs Calbarry.
A spreadsheet can produce the headline figures. The hard parts are the categories of workers, the evidence behind them, and doing it all again next reporting period.
| What you need | Spreadsheet | Consultant | Calbarry |
|---|---|---|---|
| Article 9 indicators | Formulas you build and check yourself | Calculated for you, per engagement | All seven, from one dataset |
| Categories of workers | Usually job titles or salary bands | Depends on the consultant’s method | Grades from job evaluation on the EIGE factors |
| Next reporting period | Rebuilt by hand | A new engagement | Re-run whenever the data changes |
| Audit trail | Version history, if someone keeps it | The consultant’s working papers | Every action logged; the report records its methodology version and dataset hash |
| Where salary data goes | Wherever the file is emailed | Into the consultant’s systems | Stored and processed in the EU, encrypted |
Frequently asked questions.
What is a gender pay gap analysis?
It measures the difference between what women and men in an organisation are paid, as averages and as medians, across the whole workforce and within categories of workers doing the same work or work of equal value. Under the EU Pay Transparency Directive it also covers variable pay, the share of women and men who receive it, and the share of women and men in each pay quartile.
Which companies must report, and when?
Employers with 250 or more workers report every year, starting by 7 June 2027. Employers with 150 to 249 workers report by 7 June 2027 and then every three years. Employers with 100 to 149 workers report by 7 June 2031 and then every three years. Each report covers the previous calendar year. Employers with fewer than 100 workers may report voluntarily, and national law can require them to.
What is the difference between the adjusted and unadjusted pay gap?
The unadjusted gap is the raw difference in average pay between women and men, and it is what Article 9 asks you to report. The adjusted gap is what remains after documented, gender-neutral factors are taken into account. It helps you see whether a gap can be justified, which matters if the unadjusted gap reaches 5%.
What happens if our gap is above 5%?
If the gap in average pay between women and men in a category of workers is 5% or more, and you can neither justify it on objective, gender-neutral criteria nor remedy it within six months of submitting your report, Article 10 requires a joint pay assessment with your workers’ representatives.
Can we do a pay gap analysis in Excel?
Yes, for the headline figures. A spreadsheet struggles with what the Directive adds on top: categories of workers based on job evaluation, a record of how each number was produced, and repeating the work every reporting period without starting over.
Where is our salary data stored?
In the European Union. Production data is stored and processed only in the EU. Salaries and personal data are encrypted, and each company’s data is locked with its own key.
Pay transparency, explained.
- How to do a gender pay gap analysisThe work in the order you will do it: scope, data, categories of workers, the seven Article 9 indicators, and sign-off.
- Adjusted vs unadjusted gender pay gapWhich gap the Directive asks you to report, what the adjusted gap adds, and a worked example where the two differ by more than 25 points.
- Joint pay assessment and the 5% ruleThe three conditions in Article 10, what the assessment must contain, the six-month window, and how to prepare.
- Work of equal value and job evaluationThe Article 4 criteria, how job evaluation turns them into grades, and the biases that undervalue work mostly done by women.
Talk to us about your report.
Book a demo and we’ll walk you through a pay gap analysis, from import to the Article 9 report, and answer questions about your situation.