Once gaps are uncovered, especially unexplained ones, the immediate question is: what now?
The Directive's expectation:
If pay gaps of 5% or more can't be justified, you must:
- Carry out a joint pay audit
- Develop a corrective action plan within six months
- Involve employee representatives in most cases
How to approach it thoughtfully:
- Start with a pay equity review
- Identify gaps and test whether they're explainable
- Prioritise high-risk areas, like wide gaps or senior roles
- Use structured tools
- Apply objective, gender-neutral criteria
- Use benchmarking and internal frameworks to guide decisions
- Avoid blunt fixes (e.g. raising all salaries by a flat percentage)
- Communicate with care
- Set expectations early
- Share principles before numbers
- Where possible, align corrections with promotion or review cycles
- Plan for the long term
- Budget for phased corrections if needed
- Share anonymised results with employee reps or works councils
- Commit only when you're ready to follow through
- Support managers
- Equip them to answer tough questions
- Provide escalation channels
- Reinforce that transparency is about fairness, not blame
See also: How should companies calculate gender pay gap?