# 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.


**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](https://eur-lex.europa.eu/eli/dir/2023/970/oj) 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.

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## 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 (first reporting signalled for 2028), the Netherlands targets 1 January 2027 (wetsvoorstel before the Tweede Kamer since 21 May 2026), and France tabled its projet de loi in Parliament in July 2026 — replacing the Index de l'égalité professionnelle, with entry into force expected around 1 January 2028. 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.

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## 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; the NL 1 January 2027 and FR ~1 January 2028 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.

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## How to Use This Template

1. **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.
2. **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.
3. **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?
4. **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.
5. **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.
6. **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](/eu-regulations/gender-pay-gap-reporting); for the directive itself — pay history bans, salary-range disclosure, information rights — see the [EU Pay Transparency Directive guide](/eu-regulations/eu-pay-transparency-directive).

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## Legal Basis

- **Article 9, [Directive (EU) 2023/970](https://eur-lex.europa.eu/eli/dir/2023/970/oj)** — 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.

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## 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](https://www.gov.uk/government/publications/gender-pay-gap-reporting-guidance-for-employers) — 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.

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## 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](/eu-regulations/pay-equity-software); to present your equality and pay-equity posture to enterprise buyers alongside your other compliance evidence, Orbiq's [Trust Center platform](/platform/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](/downloads/templates/eu-pay-transparency-gap-analysis.md) for AI-agent workflows.

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## Sources & References

1. [Directive (EU) 2023/970 — EUR-Lex](https://eur-lex.europa.eu/eli/dir/2023/970/oj) — Articles 4, 9, 10
2. [European Commission — EU action for equal pay](https://commission.europa.eu/strategy-and-policy/policies/justice-and-fundamental-rights/gender-equality/equal-pay/eu-action-equal-pay_en) — directive overview and equal-pay framework
3. [European Parliament — Commission answer on the transposition deadline (E-10-2025-004018)](https://www.europarl.europa.eu/doceo/document/E-10-2025-004018-ASW_EN.html) — deadline confirmed 7 June 2026, no postponement
4. [UK Government — Gender pay gap reporting: guidance for employers](https://www.gov.uk/government/publications/gender-pay-gap-reporting-guidance-for-employers) — UK metrics, snapshot dates, thresholds
5. [UK Government — Mandatory ethnicity and disability pay gap reporting commitment](https://www.gov.uk/government/news/government-commits-to-introducing-mandatory-ethnicity-and-disability-pay-gap-reporting-for-large-employers) — Equality (Race and Disability) Bill direction
6. [Lovdata — Likestillings- og diskrimineringsloven § 26 (ARP)](https://lovdata.no/dokument/NL/lov/2017-06-16-51/KAPITTEL_4) — Norwegian activity and reporting duty, biennial pay mapping