How a public university implemented the Pay Transparency Directive
Salaries at the university had been established over many years. Someone received a certain rate upon hiring, someone else an increase for seniority, and yet another person for transferring between departments or taking on a new role. Each of these decisions had its justification at the time. The problem arises when all of them need to be explained by one consistent principle, because this is precisely what the Pay Transparency Directive requires.
The university faces greater challenges than an average company in this regard. Academic staff and administrative employees work under one roof, there are hundreds of positions, and remuneration criteria must be agreed upon with trade unions. Added to this is a change that overturns previous logic: in a dispute over unequal pay, it is not the employee who proves they have been wronged, but the employer who must demonstrate that the difference results from objective reasons. And only what has been previously named and documented can be demonstrated.
Project Goal
The university needed to adapt its remuneration system to the Pay Transparency Directive (Directive 2023/970) before the regulations came into force. The difficulty was specific: academic staff and administrative employees work side-by-side in a public university.
Assumptions
- Prepare the university for the requirements of the Pay Transparency Directive and the Polish regulations implementing it.
- Evaluate positions according to the four criteria from the directive: skills, effort, responsibility, and working conditions.
- Group positions into employee categories and establish a transparent remuneration structure.
- Calculate the gender pay gap and prepare a reporting model for it.
- Go through this process together with all departments, without infringing on academic autonomy.
Actions Taken
1. Inventory and Update of Job Descriptions
We started with what actually happens in the positions, not with the names in the HR system. We organised the descriptions to reflect the scope of tasks, responsibility, and working conditions, including the differences between academic and administrative roles.
2. Job Evaluation
We evaluated positions using a single method for the entire university, based on the four criteria from the directive. Each evaluation can be logically justified, and the criteria and sub-criteria were agreed upon with employee representatives.
3. Employee Categories and Remuneration Structure
Based on the evaluation, we grouped positions into categories and established structured salary ranges for them. The structure ceased to be based on employment history and began to reflect comparable work value.
4. Pay Gap Analysis and Reporting Model
We calculated the differences in remuneration between women and men within comparable categories and prepared a reporting model for the required indicators, including the overall gap, median, gap in variable components, and gender distribution in quartiles. We also identified areas where the difference exceeds 5 percent and requires explanation.
5. Documentation, Governance, and Agreements
We established how to document the structure and salary ranges, scopes of competence, and promotion criteria. We adapted internal remuneration regulations and carried out the required agreements with unions.
6. Communication and Employee Request Handling
We prepared the university to provide employees with information about their remuneration and the average within their category. We ensured that transparency builds trust, rather than turning into an open display of injustice.
Outcome
The university now has one consistent job evaluation system where every difference in remuneration can be explained by an objective criterion, rather than employment history. The pay gap has been calculated, documented, and prepared for reporting, so the reversed burden of proof is no longer a threat. The university is ready for both the first report and employee questions about their remuneration.
If your organisation is preparing for the Pay Transparency Directive and needs to conduct job evaluations, calculate the pay gap, or organise its remuneration structure, we can help you go through this process in a way that is compliant with regulations and defensible.
