The important dimension of pay transparency: Gender-neutral job evaluation

The Directive does not simply require employers to use objective criteria when determining pay. It requires pay structures and job evaluation systems to be based on objective and gender-neutral criteria, enabling organisations to assess whether employees perform equal work or work of equal value.

This distinction is important because a job evaluation system can be objective without being gender-neutral. Many traditional approaches place significant emphasis on factors such as financial responsibility, technical expertise or operational complexity, while giving less weight to communication skills, emotional effort, coordination, relationship management or responsibility for the wellbeing of others. As a result, certain types of work—particularly roles traditionally performed by women—may be systematically undervalued.

One of the less recognised risks is that bias can enter the process before any job is scored. Organisations make decisions about which criteria are included in a job evaluation framework and which are not. If the selected criteria do not reflect the full spectrum of skills, effort, responsibility and working conditions across the workforce, the framework itself may produce biased outcomes, even when applied consistently.

This creates an important challenge for organisations implementing the Directive. Transparency may reveal pay differences, but it cannot by itself determine whether those differences are justified. Without a genuinely gender-neutral approach to evaluating work, transparency risks making existing inequalities more visible rather than addressing their root causes.

As organisations review their job architectures and prepare for compliance, they should ask not only whether their criteria are objective, but also whether they are sufficiently comprehensive and gender-neutral. The most important question may not be whether pay differences can be explained, but whether the process used to determine the value of work is fair, balanced and free from gender bias in the first place.

How can we help?

Forvis Mazars supports organisations in developing and enhancing job evaluation systems aligned with the requirements of the EU Pay Transparency Directive. Our approach includes reviewing existing job architectures, assessing alignment with the principle of equal work and work of equal value, developing objective and gender-neutral evaluation criteria, and identifying potential sources of bias within compensation frameworks. Combining expertise in pay equity, HR transformation and regulatory compliance, we help organisations build transparent, fair and sustainable reward systems that support both compliance and long-term organisational effectiveness.