Questions & Answers
The guideline stipulates that deviations of more than 5% per employee category must be justified. How are these categories defined? If the reporting pay demonstrates a difference in the average pay level of at least 5 % in any category of workers, the employer needs to justify such a difference on the basis of objective, gender-neutral criteria – otherwise, joint pay assessment is necessary.
- Gender Pay Gap
- Pay Transparency Directive
Background
ESRS S1 paragraph 97 (a) states: ‘The disclosure required by paragraph 95 shall include: (a) the gender pay gap, defined as the difference of average pay levels between female and male employees, expressed as percentage of the average pay level of male employees.’
Answer
ESRS S1 paragraph 97 (a) requires disclosure of the gender pay gap and does not include any requirements for conducting or reporting on pay assessments, and it does not include any thresholds. The quote provided by the submitter stems from the Pay Transparency Directive and refers to the obligation to conduct a joint pay assessment (Article 10). It is not applicable to ESRS per se.
Relations
Paragraph | Content |
|---|---|
Appendix A - Application Requirements | |
Metrics and targets | |
Disclosure Requirement S1-16 – Remuneration metrics (pay gap and total remuneration) | |
Metrics and targets | |
Appendix A - Application Requirements | |
Metrics and targets | |
When the undertaking includes in its sustainability statement additional disclosures stemming from (i) other legislation which requires the undertaking to disclose sustainability information, or (ii) generally accepted sustainability reporting standards and frameworks, including non-mandatory guidance and sector-specific guidance, published by other standard-setting bodies (such as technical material issued by the International Sustainability Standards Board or the Global Reporting Initiative), such disclosures shall: | |
When the undertaking includes in its sustainability statement additional disclosures stemming from (i) other legislation which requires the undertaking to disclose sustainability information, or (ii) generally accepted sustainability reporting standards and frameworks, including non-mandatory guidance and sector-specific guidance, published by other standard-setting bodies (such as technical material issued by the International Sustainability Standards Board or the Global Reporting Initiative), such disclosures shall: | |
When the undertaking includes in its sustainability statement additional disclosures stemming from (i) other legislation which requires the undertaking to disclose sustainability information, or (ii) generally accepted sustainability reporting standards and frameworks, including non-mandatory guidance and sector-specific guidance, published by other standard-setting bodies (such as technical material issued by the International Sustainability Standards Board or the Global Reporting Initiative), such disclosures shall: |