Free Pay Transparency Gap Analysis Template (2026) — Excel
Gender pay gap analysis aligned to Directive (EU) 2023/970: Article 9 metrics, category gaps, the 5% joint-assessment trigger. Free XLSX, no email gate.
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Version 1.0 · Updated Jul 17, 2026 · Free, no email required
Free Pay Transparency Gap Analysis Template (2026) — Excel
Quick answer: This free EU pay transparency gap analysis template is a downloadable XLSX (plus PDF guide and machine-readable Markdown) that computes the gender pay gap metrics Directive (EU) 2023/970 Article 9 requires — mean and median gaps in basic and variable pay, quartile distribution, and the gap per category of workers — and flags every category that crosses the 5% Article 10 threshold, tracks the objective-justification analysis, and counts down the six-month remedy window that decides whether a joint pay assessment becomes mandatory. It includes a worked example, the full Article 10(2) joint-assessment checklist, and the UK and Norway reporting parallels.
The mechanics matter more than they look. The 5% trigger is tested per category of workers, not company-wide — a comfortable 2% overall gap can hide a 9% gap in one job family, and that single category can put you into a mandatory joint pay assessment with workers' representatives. The template is built around exactly that failure mode: category-level analysis first, company-wide metrics second, and a trigger logic that mirrors the directive's three cumulative conditions rather than the common "5% means audit" shorthand.
Key Takeaways
- Seven Article 9 metrics, one file. Mean and median gaps (basic and complementary/variable), the proportions of women and men receiving variable components, quartile distribution, and the per-category gap — the full first-report data set, due 7 June 2027 for employers with 150+ workers (annually for 250+; 100–149 follow by 7 June 2031).
- The trigger is three conditions, not one. A joint pay assessment becomes mandatory only when a category gap is ≥5%, cannot be justified by objective gender-neutral criteria, and is not remedied within six months of report submission. The template tracks all three per category — including the remedy countdown most trackers ignore.
- Categories decide compliance. The analysis stands or falls with how you define categories of workers (same work or work of equal value, on objective gender-neutral criteria). The template forces an explicit category register before any gap math.
- Transposition is a patchwork. July 2026 transposition trackers list only Italy, Slovakia, Lithuania, and Malta as fully transposed at the 7 June 2026 deadline; Germany targets 2027 legislation, the Netherlands and France 1 January 2027. The directive's timetable remains the anchor — waiting for your national law is how the 2026 data year gets lost.
- UK and Norway differ on purpose. The UK Equality Act regime (250+, six metrics, April snapshot dates) and Norway's ARP (50+, biennial pay mapping by gender and equal value) are both narrower and broader in places — the template's jurisdiction sheet maps the differences so pan-European HR teams run one analysis.
What's Inside the Template
The XLSX contains six sheets with formulas and dropdowns pre-wired; the PDF is a field guide; the MD variant carries the full logic for AI-agent workflows.
1. Category Register & Gap Analysis
One row per category of workers — the analytical core:
| Field | Example | Basis |
|---|---|---|
| Category (same work / equal value) | Software Engineering — Grade 3 | Art 9(1)(g), Art 4 |
| Definition criteria | Skills, effort, responsibility, working conditions | Art 4(4) |
| Headcount F / M | 14 / 23 | Art 10(2)(a) |
| Average basic pay F / M | €68,400 / €73,900 | Art 9(1)(g) |
| Average variable components F / M | €4,100 / €6,050 | Art 9(1)(g) |
| Basic gap % (computed) | 7.4% | — |
| ≥5% flag (computed) | YES | Art 10(1)(a) |
| Objective justification analysis | Under analysis / Justified / Not justified | Art 10(1)(b) |
| Report submission date + remedy deadline (computed, +6 months) | 2027-06-07 → 2027-12-07 | Art 10(1)(c) |
| Joint assessment required (computed) | ≥5% AND not justified AND not remedied | Art 10(1) |
2. Article 9 Report Metrics
The company-wide report data set: mean and median gender pay gap in basic pay, mean and median gap in complementary/variable components, and the proportion of female and male workers receiving complementary or variable components — with weighted-mean formulas fed from the category register and input cells for the medians (which need your raw payroll distribution, not category averages; the sheet says so rather than faking it).
3. Quartile Distribution
The four equal-sized pay bands with female/male counts and computed proportions per quartile — Article 9(1)(f), and the metric most likely to expose vertical segregation that averages hide.
4. Joint Pay Assessment Checklist
The seven Article 10(2) elements as tracked checklist rows with status dropdowns — gender composition per category, average pay levels incl. variable components, identified differences, jointly-established objective reasons, the family-leave pay-improvement proportion, remediation measures, and the evaluation of any previous assessment.
5. Reporting Timeline & Jurisdictions
Thresholds and deadlines pre-loaded: 250+ annual from 7 June 2027; 150–249 three-yearly from 7 June 2027; 100–149 three-yearly from 7 June 2031 — plus national-variation flags (Slovakia's 15 April annual deadline; German draft timing; NL/FR 1 January 2027 targets) and the UK and Norway rows for group-wide planning.
6. Worked Example
A completed analysis for the fictional Aurora Software GmbH (320 workers, 7 categories) — including one category that crosses the 5% line, its justification analysis, and the remedy-window decision, so the trigger logic is demonstrated end to end.
How to Use This Template
- Define categories first. Build the category register from your job architecture — same work or work of equal value, on objective, gender-neutral criteria (skills, effort, responsibility, working conditions). This step decides whether your analysis will survive scrutiny; gap math on arbitrary groupings is rework waiting to happen.
- Load pay data per category. Average basic pay and average complementary/variable components, split by gender, per category. Include every component — bonuses, allowances, benefits in kind count.
- Read the flags. The sheet computes each category's gap and flags ≥5%. For each flagged category, run the justification analysis: can the difference be fully explained by objective, gender-neutral criteria?
- Use the remedy window. For unjustified gaps, you have six months from report submission to remedy before the joint pay assessment becomes mandatory. The computed deadline column makes that window a project plan, not a surprise.
- Complete the Article 9 sheet. Fill the company-wide metrics and quartiles for the report itself, and reconcile them with your category-level story before anything is submitted.
- Repeat on your reporting cadence. Annual for 250+, three-yearly below — and after any restructuring that changes categories.
For the reporting obligations across all three European regimes, see our gender pay gap reporting guide; for the directive itself — pay history bans, salary-range disclosure, information rights — see the EU Pay Transparency Directive guide.
Legal Basis
- Article 9, Directive (EU) 2023/970 — gender pay gap reporting for employers with 100+ workers: the seven metrics including the per-category gap (Art 9(1)(a)–(g)), with first reports by 7 June 2027 (250+, then annually; 150–249, then three-yearly) and 7 June 2031 (100–149, three-yearly).
- Article 10, Directive (EU) 2023/970 — joint pay assessment, in cooperation with workers' representatives, where all three Article 10(1) conditions are met (≥5% category gap, no objective gender-neutral justification, no remedy within six months of report submission); content per Article 10(2)(a)–(g).
- Article 4, Directive (EU) 2023/970 — same work and work of equal value: categories must rest on objective, gender-neutral criteria including skills, effort, responsibility, and working conditions.
- Transposition status (July 2026): the deadline was 7 June 2026; per the July 2026 law-firm transposition trackers, Italy, Slovakia, Lithuania, and Malta transposed on time while most member states are targeting 2027 legislation, and the Commission has signalled infringement steps for late transposition. Employers planning against national laws instead of the directive's data years are planning to be late.
UK, Norway, and the EEA
UK: the directive does not apply, but gender pay gap reporting has been mandatory since 2017 under the Equality Act 2010 regulations — employers with 250+ employees publish six metrics (mean/median hourly gap, mean/median bonus gap, bonus proportions, quartiles) against 31 March (most public bodies) or 5 April snapshot dates. Two differences matter for group-wide analysis: the UK regime has no category-level test and no joint-assessment trigger, and its quartile method is prescribed. The UK government has committed to extending mandatory reporting to ethnicity and disability pay gaps for large employers via the Equality (Race and Disability) Bill. UK-headquartered groups with EU entities comply with the directive in those member states regardless.
Norway / EEA: Norway's aktivitets- og redegjørelsesplikten (ARP) already requires all public employers and private employers with 50+ employees (20–49 on request of employee representatives) to run a pay mapping (lønnskartlegging) by gender and work of equal value every two years and publish the results in the equality statement. The directive is EEA-relevant, and the government announced in November 2025 that implementation work has begun; until incorporation, ARP is the binding regime — at a lower headcount threshold than the directive, but without its prescriptive metrics or the 5% trigger. The template's category-level analysis satisfies the ARP equal-value mapping logic as well.
From Annual Panic to Standing Analysis
The directive's design punishes one-off exercises: the report is periodic, the remedy window is short, and the joint-assessment trigger reads from data you submitted months earlier. Teams that treat the gap analysis as a standing register — categories maintained, pay data refreshed, flags reviewed quarterly — enter each reporting year with decisions already made. For the software side of that workflow, see our pay equity software comparison; to present your equality and pay-equity posture to enterprise buyers alongside your other compliance evidence, Orbiq's Trust Center platform keeps the documentation governed and buyer-ready with EU data residency. The machine-readable Markdown variant of this template is available at /downloads/templates/eu-pay-transparency-gap-analysis.md for AI-agent workflows.
Sources & References
- Directive (EU) 2023/970 — EUR-Lex — Articles 4, 9, 10
- European Commission — EU action for equal pay — directive overview and equal-pay framework
- European Parliament — Commission answer on the transposition deadline (E-10-2025-004018) — deadline confirmed 7 June 2026, no postponement
- UK Government — Gender pay gap reporting: guidance for employers — UK metrics, snapshot dates, thresholds
- UK Government — Mandatory ethnicity and disability pay gap reporting commitment — Equality (Race and Disability) Bill direction
- Lovdata — Likestillings- og diskrimineringsloven § 26 (ARP) — Norwegian activity and reporting duty, biennial pay mapping
Download this template
Version 1.0 · Updated Jul 17, 2026 · Free, no email required
Frequently Asked Questions
What must employers report under Article 9 of the EU Pay Transparency Directive?
Employers with 100 or more workers must report seven metrics: the mean and median gender pay gap, the mean and median gap in complementary or variable components (bonuses, allowances, benefits), the proportion of female and male workers receiving complementary or variable components, the proportion of female and male workers in each quartile pay band, and the pay gap by category of workers performing the same work or work of equal value — split into ordinary basic salary and complementary or variable components.
When are the first EU gender pay gap reports due?
Employers with 250 or more workers report annually and employers with 150–249 workers report every three years, both starting by 7 June 2027 based on 2026 data. Employers with 100–149 workers report every three years starting by 7 June 2031. Employers below 100 workers have no EU-level reporting duty, though member states may set lower thresholds and some national transpositions add earlier or stricter deadlines — Slovakia, for example, requires annual reports by 15 April.
What triggers a joint pay assessment under Article 10?
Three conditions must all be met: the Article 9 report shows a gender pay gap of at least 5% in average pay within any category of workers; the employer cannot justify the gap by objective, gender-neutral criteria; and the employer does not remedy the unjustified gap within six months of submitting the report. Only when all three hold must the employer carry out a joint pay assessment together with workers' representatives. The six months are therefore a remedy window — fixing an unjustified gap in time avoids the assessment obligation.
What must a joint pay assessment contain?
Article 10(2) requires seven elements: the proportion of female and male workers in each category of workers; average female and male pay levels including complementary or variable components per category; any differences in average pay between women and men per category; the reasons for those differences based on objective, gender-neutral criteria established jointly with workers' representatives; the proportion of workers who received a pay improvement after returning from family-related leave; measures to address unjustified differences; and an evaluation of measures from any previous joint pay assessment.
What is a category of workers under the directive?
A category groups workers performing the same work or work of equal value, defined by the employer using objective, gender-neutral criteria such as skills, effort, responsibility, and working conditions — typically implemented through job architecture: job families, grades, or equal-value groups. The category definition is decisive for compliance because the 5% joint-assessment trigger is tested per category, not company-wide, so a small company-wide gap can hide category-level gaps that trigger Article 10.
Does the EU Pay Transparency Directive apply in the UK?
No. The UK has its own regime under the Equality Act 2010 regulations: employers with 250 or more employees publish six gender pay gap metrics annually (mean and median hourly pay gap, mean and median bonus gap, bonus proportions, and quartile distribution), with snapshot dates of 31 March for most public bodies and 5 April for others. UK employers with EU operations must comply with the directive in those member states. The UK government has also committed to mandatory ethnicity and disability pay gap reporting for large employers via the Equality (Race and Disability) Bill.
How does the directive apply in Norway?
Norway already runs a demanding national regime: under the activity and reporting duty (aktivitets- og redegjørelsesplikten, ARP), all public employers and private employers with 50 or more employees must map pay by gender and work of equal value every two years and publish the results in their equality statement. The EU directive is EEA-relevant, and in November 2025 the Norwegian government announced work on implementing it into Norwegian law — until then ARP remains the binding regime, in several respects at a lower threshold than the directive.