Method and limits
Updated 24 September 2026
We deliver supporting documents and a record of decisions. Responsibility for remuneration remains with the employer.
Amendment status as of 21 October 2026: print 300 has passed its first reading in the Chamber of Deputies and is now with the committees. Based on the Government bill (parliamentary print 300/0, circulated 8 Sep 2026). The law is not yet in force and the text may change in the Chamber of Deputies.
What we prepare for you
- A remuneration system you can adopt as an internal regulation: purpose, pay components, how pay is set and a catalogue of job groups ranked by value of work with written justification for each criterion. § 109a Labour Code, from 1 January 2027, every employer.
- The gap figures per job group that go into the report to the Ministry: from averages, by job group, annual and hourly. § 37i Labour Inspection Act; first in 2028 for 2027; filed only by employers with 150+ annual work units.
- The response you must give an employee who asks: one letter per job group, or a sentence explaining why no figure can be given. § 306b Labour Code, from 2028.
- Parts a) to d) of the written pay assessment. Parts e) and g) we do not produce. § 287b Labour Code.
- Which job groups exceed the 5% threshold, and what it is measured on. Gross hourly gap within the group, from averages. No model, no free parameter. § 287a Labour Code.
- Pay bands and two kinds of inconsistency visible to the naked eye: higher-valued work paid less than lower-valued work, and two groups of equal value whose bands do not overlap at all.
- The minimum pay to disclose at every hire, with a record. The offer is assessed, and not the applicant as a person. § 30(3) Labour Code, from 2027.
- A record of decisions that shows who decided what. Entries cannot be edited or deleted: enforced at the database level as well as in the application. Confirming a proposal without change is also a decision and is recorded in the same way.
Limits of the method
We do not give one ‘adjusted gap’ figure. It depends on how individual jobs are rated, and one step in one group can move it by more than the whole figure. You get a direction and a lower bound, or a statement that no direction can be established. Points 1–7 do not depend on this: they rest on averages.
Equal rating does not always mean equal work. Two jobs can reach the same value with very different profiles. The system lists such pairs by name and lets you decide; the decision goes into the record.
Small groups get no figure. Below the sample threshold the output states why, because a figure could reveal an individual's pay. We distinguish suppressed (a gap exists but may not be shown) from not comparable (no women or no men in the group).
We compute the 5% threshold from pay for work, not from benefits. Where benefits differ between groups or genders, our threshold may underestimate the statutory one, and every such figure carries a note saying so.
We do not provide legal services. The system refuses to issue a document that claims compliance: that is a guard in code. What we do not produce: part e) and g) of the assessment, the annual notice to employees under § 306b, the benefits system under § 306a, review of confidentiality clauses under § 346a, consultation with trade unions, and the report form itself (the regulation does not yet exist).
No lawyer has reviewed this yet. Until one has, every statement here is our reading of the draft amendment and should not be taken as legal advice. When that changes, we will say so here with a date.