Guide · Job evaluation · EU Pay Transparency

Gender-neutral job evaluation for small companies: a practical guide

Last updated: 2026-10-01 · ~9 min read

The EU Pay Transparency Directive asks one question every employer will have to answer: which jobs in your company are of equal value, and are they paid equally? For companies of 5–100 people, the answer starts with a simple, defensible job evaluation. Here is how to run one, based on the European Commission and EIGE 2026 toolkit.

Short answer

Evaluate the job, not the person

Gender-neutral job evaluation compares every role against the same four objective factors — skills, responsibility, effort and working conditions — instead of job titles, habit or market folklore. The ranking it produces becomes the backbone of your pay grades.

It is not a 300-page project. A small company can run it with two to five people, a spreadsheet and honest conversations. What matters is that every decision is justified against the factors, and documented.

Step zero

Pick the method that fits your size

5–9
Method

Graduated factor comparison — score each job 0–5 on each subfactor

Who runs it

Owner/manager, ideally with one other person

10–49
Method

Pair comparison — compare every job with every other job

Who runs it

1–2 people: owner/manager + one worker who sees all roles

50–100
Method

Pair comparison; full point-factor method above ~15 distinct roles

Who runs it

A small committee of 2–5 people from different departments

If you expect significant growth, starting directly with the more robust point-factor method can save a restructuring later.

The framework

Four factors, applied to every job

01

Skills

Knowledge, interpersonal and communication skills, problem-solving, planning and organisation, physical skills.

02

Responsibility

For people, goods and equipment, information and financial resources.

03

Effort

Mental, psychosocial and emotional, and physical effort.

04

Working conditions

Physical, psychological or emotional environment, and organisational environment.

Before comparing jobs, agree as a team what each subfactor means in your company, with real examples.

Where bias hides

Four ways a 'neutral' evaluation goes wrong

  • Active listening, coordination or emotional regulation — common in women-dominated roles — are treated as personality traits rather than professional skills.
  • Responsibility is defined narrowly as managing staff or budgets, missing constant responsibility for other people's wellbeing.
  • Effort means visible physical effort; emotional and mental load (tense clients, parallel deadlines) goes uncounted.
  • Working conditions focus on physical hazards and miss psychosocial risks in indoor, public-facing jobs.
The process

Eight steps, from bias check to follow-up

1

Understand and prevent bias

A 5-minute self-check: what do I picture as 'demanding work'? Which jobs do I instinctively rate high, and why? Do I use gendered terms for some roles?

2

Get started

Set up a small evaluation team, involve representatives if they exist, write a one-page project outline and tell everyone: we evaluate jobs, not people, and no one's pay will go down.

3

Gather job information

Use existing job descriptions, contracts and pay records; fill gaps with short conversations; record the gender of job holders; respect GDPR — collect only what you need.

4

Evaluate the jobs

Hide job titles (‘job 1’, ‘job 2’), compare against the factors, justify each decision in one or two lines, then check whether women-dominated jobs cluster at the bottom.

5

Classify and build pay grades

Check whether pay follows the ranking; group similar scores into 3–5 grades with midpoints and ranges. Close gaps by raising pay, never by lowering it.

6

Check variable pay

Bonuses, allowances, 13th-month pay and benefits in kind must be equally accessible within a grade — including for part-time staff and people returning from leave.

7

Fix titles and descriptions

Rewrite around skills: ‘server’ not ‘waitress’, ‘able to prioritise and coordinate multiple tasks’ not ‘natural multitasker’.

8

Track and follow up

One owner, a shared log, a rolling review of about a third of jobs per year and a full system review every 3–5 years. Link recruitment, pay decisions and reviews to the scores.

The split

With or without employee representatives

If you have a union, works council or collective agreement

  • Notify representatives early, before you start.
  • Agree the evaluation criteria with them — this is a Directive requirement.
  • Invite them into the comparison or a review session; share results before pay changes are final.
  • Record notifications, minutes and decisions; hold an annual review meeting.

If you don't

  • You are not required to create representation for this purpose.
  • Talk to people individually or in small groups so the process isn't imposed.
  • Ask a second person to cross-check profiles and the ranking for fairness.
  • Share a short annual summary and give people a known way to raise concerns.
From ranking to pay

A simple pay-grade structure

3–5

grades are usually enough for a small company

€1,800

example midpoint for the lowest grade — check against the legal minimum wage

×1.1–1.2

progression factor between grade midpoints (e.g. €1,800 × 1.15 = €2,070)

20–40%

typical width of the pay range around each midpoint

Don't build new ranges on existing salaries — they may already contain historical bias. Balance market data with internal fairness.

Worked example

What a 20-person freight forwarder discovered

In the guide's fictitious freight company, the team's first instinct was that the physically demanding, male-dominated warehouse role was 'obviously' more skilled than the customs and documentation clerk.

Scored against the factors, the customs clerk ranked higher: interpreting changing regulations across several countries and carrying responsibility for fines and delayed shipments outweighed the warehouse role's physical effort.

The women-dominated customs role (grade 3) had been paid less than the men-dominated truck driver role (grade 2). The fix: a pay increase for the customs clerk role, confirmed with the union representative — and no reduction anywhere else.

How MERAKI HR can help

Choose the level of support you need

Some companies run the process alone with the guide. Others want a second pair of eyes, or someone to build the whole structure with them.

Know where you stand first

Prism ClearPay's Pay Transparency Readiness Assessment gives you a structured readiness report on job architecture, pay criteria and reporting — a solid brief before any project.

Take the readiness assessment →

Consultancy

Job architecture, evaluation criteria, pay bands and documentation designed with you and reviewed against the Directive and national transposition.

Explore consultancy →

Hands-on HR

Fractional or project-based support to run the evaluation itself: workshops, job profiles, pair comparisons, grades and the communication to employees.

See hands-on services →

Prism ClearPay — the upcoming tool

We are building a digital tool to keep job evaluation, pay grades and transparency reporting in one place. Join the waitlist for early access.

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Free download

Get the full 12-page guide

Every step in detail, the with/without-representatives paths side by side, the factor plan and two worked examples of 20-employee companies.

Preview and download the guide
FAQ

Questions employers ask

What is gender-neutral job evaluation?

A structured way of judging the value of each job — not the person in it — against the same objective factors: skills, responsibility, effort and working conditions. It is the basis for comparing 'work of equal value' under the EU Pay Transparency Directive.

Which job evaluation method should a small company use?

According to the 2026 EC/EIGE toolkit: 5–9 employees use a simplified graduated factor comparison; 10–49 use a simplified pair comparison; 50–100 use pair comparison, switching to the full point-factor method above roughly 15 distinct job roles.

Do we need employee representatives to do job evaluation?

No. The Directive requires the criteria to be agreed with workers' representatives only where they exist. Without a union, works council or collective agreement you run the process internally and replace formal consultation with direct communication.

What if the evaluation reveals a pay gap?

Close it by raising pay for the undervalued job — never by lowering pay for the higher-paid one. You may need to reclassify the job into a different grade.

How many pay grades does a small company need?

Usually 3–5. Set a midpoint for the lowest grade, apply a progression factor of about 1.1–1.2 for each higher grade, and give each grade a range typically 20–40% wide.

Source: adapted and condensed from European Commission & European Institute for Gender Equality (EIGE) (2026), “EU-wide guidelines on gender-neutral job evaluation and classification: Step-by-step toolkit”, Publications Office of the European Union, Luxembourg. MERAKI HR is not affiliated with the European Commission or EIGE.

This article is informational and does not constitute legal advice. Check national transposition rules for your country before acting.