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Directive (EU) 2023/970

Work of equal value under the EU Pay Transparency Directive

Equal pay covers different jobs of equal value, not only identical ones. Employers need pay structures that compare jobs with objective, gender-neutral criteria: skills, effort, responsibility and working conditions.

Last checked 23 October 2026

What the directive says

Article 4 of Directive (EU) 2023/970 requires employers to have pay structures that ensure equal pay for equal work or work of equal value. Member states must make analytical tools or methods available for assessing the value of work.

Pay structures shall be such as to enable the assessment of whether workers are in a comparable situation in regard to the value of work on the basis of objective, gender-neutral criteria agreed with workers’ representatives where such representatives exist. […] They shall include skills, effort, responsibility and working conditions, and, if appropriate, any other factors which are relevant to the specific job or position.

Directive (EU) 2023/970, Article 4(4)

Read the full article in the official text on EUR-Lex. The directive also states that relevant soft skills must not be undervalued.

What it means in practice

Different jobs can be equal

Two roles with different titles and tasks are of equal value when they demand a comparable level of skills, effort, responsibility and working conditions. The comparison is about the job, not about the person doing it or how well they perform.

Categories of workers come first

Most obligations in the directive work per category of workers doing the same work or work of equal value: pay information requests, the seventh reporting measure and the 5% test for a joint pay assessment. Without categories, those obligations cannot be met.

The criteria are agreed and gender-neutral

The criteria are agreed with workers’ representatives where they exist, may not be based directly or indirectly on sex, and must be applied consistently.

Comparisons can reach beyond one employer

Under Article 19, the comparison is not limited to the same employer when a single source sets the pay conditions, nor to workers employed at the same time. Where no real comparator exists, statistics or a hypothetical comparison can be used.

How to prepare

  • Describe each job by what it requires, not by who holds it.
  • Choose a job evaluation method: one from your collective agreement, a commercial system or your own, as long as it is objective and gender-neutral.
  • Agree the criteria and their weights with workers’ representatives where they exist.
  • Group jobs into categories of equal value and document why each job sits where it does.
  • Test the categories against pay data to see which gaps appear and which you can justify.
  • Keep the categories current when jobs change or new roles are created.

Questions employers ask

The directive lists skills, effort, responsibility and working conditions, plus other relevant factors. National laws and guidance decide how strictly the list applies. Check your country’s rules.

Evenpay keeps your job architecture, levels and categories in one place, so the same grouping feeds pay analysis, reporting and answers to pay information requests. See how job architecture works in Evenpay.