Ministry of Labour publishes methodology on equal pay

The methodology sets out the principles of equal pay and explains the terminology involved. The concept of "pay" is to be understood broadly, beyond the definition of "wage" under the Labour Code. Alongside basic pay, it also covers supplementary components. For example wage compensation, allowances and wage premiums, a transport contribution, the private use of a company car and other, including occasional, monetary and non-monetary benefits.

What companies need to do now

The immediate task for employers is to put in place a transparent pay structure by 31 July 2026 - that is, a set of rules that ensures pay is determined objectively according to the value of the work. The Ministry also offers a concrete tool and job evaluation methodology for assessing job positions, which draws on the methodology of the European Institute for Gender Equality (EIGE) and the recommendations of the International Labour Organization (ILO), while adapting it to the national context.

We therefore recommend that employers who have already applied other evaluation methodologies supplement them with any missing evaluation criteria. Both the equal pay act and the EU directive set out complexity, responsibility, effort and working conditions as the main factors. Where employee representatives are present at an employer, their involvement in the job evaluation process is essential. The pay structure must then be made accessible to employees.

Reporting

The reporting obligation continues to apply to companies with more than 150 employees. They will submit their first pay report by 7 June 2027, covering the period from August to December 2026.

For a detailed look at the new obligations, findings from our survey of 129 companies and a practical path to compliance, see our joint publication with Humanet.