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Pay reporting

The EU report's Article 9 indicators

Understand the seven Article 9 indicators and check the corresponding sections of your pay gap report.

Written By Karl

Last updated 1 day ago

Article 9 of the EU Pay Transparency Directive specifies seven indicators for employers subject to its reporting requirements. Use the table below to check the corresponding sections of your EU Pay Transparency report. Section names alone do not confirm that the selected data, pay components and reporting period meet every applicable requirement.

Scope: this is a reference to the EU Directive, not a country-specific filing guide or certification of a generated report. Check the applicable national requirements before submission.

Indicator

What to check

Report section

(a) Gender pay gap

The difference in mean pay levels between women and men, relative to men's mean pay.

Overall Pay Gap

(b) Gap in complementary or variable components

The mean gap for these additional pay components, not just bonuses or commissions.

Variable Pay Gap

(c) Median gender pay gap

The difference in median pay levels, relative to men's median pay.

Overall Pay Gap

(d) Median gap in complementary or variable components

The median gap for these additional pay components.

Variable Pay Gap

(e) Share receiving complementary or variable components

The proportion of women and of men receiving these components.

Variable Pay Access

(f) Quartile pay bands

The proportion of women and men in each of the four pay quartiles.

Pay Quartiles

(g) Gap by category of workers

The gap for each category performing the same work or work of equal value, with a breakdown between basic wage or salary and complementary or variable components.

Pay Gap by Category

Category-level basic and variable pay

Go to Pay Equity → Reports and use the Pay Gap by Category report component to view separate basic-pay and complementary or variable-pay breakdowns by category of workers. For Article 9 indicator (g), review both breakdowns rather than relying solely on the overall pay-gap result for a category or on organisation-wide variable-pay figures.

Before submission, check that all required category-level figures are included in the output, along with the category row limit, reporting year, pay source and employee coverage described in Creating a pay gap report.

Check component coverage before sharing

The Directive's term complementary or variable components is broader than a label such as Variable Pay Gap. Check which of your components are included and inspect the export, including the basic-pay and additional-component breakdown for indicator (g). See Setting up salary components and benefits. If you cannot reconcile the output with your source data or reporting requirements, contact Evenpay support before relying on it for submission.

Recipients and publication

Under Article 9, all seven indicators go to the designated authority. Indicators (a)–(f) form the public reporting information. Indicator (g) must also reach workers and their representatives, and the labour inspectorate and equality body on request. Follow national rules and the applicable privacy safeguards when distributing reports.

The EU Pay Transparency (Public) template leaves out (g). Check the selected template and its output before sharing; do not treat an internal or auditor data bundle as a public report.

Good to know

  • Review the report's selected grouping against the categories you use for the same work or work of equal value. Do not assume that a report grouping label automatically matches the equal-value grouping configured elsewhere. See Work of equal value groups.

  • Small groups are suppressed. See Small groups and suppression.

  • The template also has a Management Sign-off section. Review the figures and methodology before signing off.

Source

Directive (EU) 2023/970, Articles 3, 9 and 12. EU indicator wording checked on 23 October 2026. For filing scope, dates, submission routes and any additional requirements, consult the applicable national rules.

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