Complying with the Spain Remuneration Register report
This article provides information on legally required pay equity reporting in Spain. It gives an overview of which employers need to take action, what the deliverables are, how to get started, and how to use the PayAnalytics software to help meet local requirements.
In Spain, a new pay equity legislation took effect in 2021. Royal Decree 902/2020 uses specific measures to establish gender pay equity and eliminate both direct and indirect pay discrimination. It focuses on the connection of pay transparency to ensure that men and women are compensated equally for work of equal value. In fact, the legislation has specific requirements focused on equal pay for work of equal value, and it spells out how to classify job roles and how to analyze pay data by gender.
The decree established four key pay transparency tools:
Remuneration register. - this document contains aggregated and disaggregated pay data for all the organization’s employees. This is a way of identifying any unadjusted gender pay gaps.
Remuneration audit. - this analysis of pay data focuses on finding any adjusted gender pay gaps. It also serves to identify how the employer can close these gaps.
Job evaluation system. - this evaluation makes sure that job classifications are objectively based and do not perpetuate bias or discrimination. This tool is used to establish equal pay for work of equal value.
Employee’s right to information. - to uphold pay transparency, Spain’s law establishes that employees are entitled to information about pay.
In conjunction with Royal Decree 902/2020, the government also implemented Royal Decree 901/2020, which is a second decree that concerns equality plans and how to register them. An equality plan is a document that helps to eliminate gender discrimination by specifying measures to ensure equal treatment and equal opportunities for men and women. These equality plans are tied to companies’ remuneration audits. Within the equality plan, there is a diagnosis report that should contain the results of the remuneration audit, along with other measures.
In this article we will break down the requirements for the pay gap reporting in Spain and help you answer four questions:
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Please keep in mind that the articles in the PayAnalytics Help Center do not offer legal advice.
1. Who does it apply to?
All companies must complete a remuneration register annually, and companies with 50 or more employees also need to do a job evaluation, a remuneration audit, and an equality plan.
An equality plan is required for employers with 50 or more workers. Organizations with fewer employees may also be required to do an equality plan, either by a collective agreement or as part of a sanctions process. Companies that are not required to create an equality plan can still do so voluntarily. Equality plans have a maximum duration of four years. After four years, a new analysis and remuneration audit should be conducted and a new equality plan created. Once an equality plan is created, it needs to be publicly registered.
To sum up:
Remuneration register - a remuneration register is required for all companies of all sizes, including public administration organizations. The register should cover one calendar year and should be done annually.
Remuneration audit - this is obligatory for employers with 50 or more employees. However, smaller organizations may opt to conduct a remuneration audit as well.
Job evaluation system - for companies with 50 or more employees, the job evaluation is mandatory and must be used in both the remuneration audit and the remuneration register.
2. What is the requirement?
The requirements for the remuneration register are to include all the company’s employees. This includes management and senior management. The data must be broken down by gender and by professional classification. Professional classification may include employees’ positions or job roles, professional categories, or jobs of equal value.
For the whole organization, the remuneration register should report the mean and the median of the following elements, along with the aggregated information, i.e. total compensation:
Base salary
Ordinary compensation components - such as education or seniority
Extraordinary compensation components - such as overtime or travel required by the job.
The remuneration register does not need to be submitted to the government. However, employers must keep it on hand and ready for inspection upon request by any employees or by Spain’s Ministry of Labor. If the company’s employees have legal representatives, then employees are allowed to view the whole content of the remuneration register. Otherwise, employees can view only the overall percentages.
3. How does PayAnalytics help you to meet the requirement?
In PayAnalytics you can generate a remuneration register in Excel spreadsheet form by following these steps:
Preparing your dataset
Note that a dataset containing at least the following data needs to be imported prior to generating the remuneration register report:
Unique employee ID (mandatory for all datasets),
Gender which for reporting purposes constitutes either male or female, which are not further defined in regulations,
Professional classification groups,
Base salary and compensation component (ordinary and extraordinary).
Generating the report:
When you have uploaded your dataset with the necessary fields, you select the dataset and navigate to the Report section in the left navigation bar. Then you click, Create new report, and under Government mandated reports you select the Remuneration register (Spain), as presented on the following picutre:
Creation of new report
You will be redirected to the report configuration page, where you'll first need to select the groups to break down the data and categorize your employees by professional classification and select your base salary, as shown on the following illustration:
Selecting options for government mandated reports
The next step is to identify the variables in your dataset that correspond to salary components, distinguishing between ordinary salary components and extraordinary ones. While all variables in the dataset will be presented for selection, you only need to focus on selecting those related to salary components. The example is illustrated on the following picture:
Choosing salary components
Once completed, click Generate Report to download the Excel spreadsheet.
4. Which steps should we take next?
In addition to creating the remuneration register report, fulfilling Spain’s other pay equity requirements can be done in PayAnalytics as well.
With the built-in Job evaluation feature, click here to learn more, you can establish any job’s value with objective, unbiased factors. According to the requirements, all organizations with more than 50 employees are required to perform a job evaluation, and then use that job evaluation to their remuneration register and remuneration audit.
Larger employers are obliged to justify any gender pay gaps over 25% in the remuneration register. In a pay equity analysis feature, you can highlight how specific factors within an organization influence pay. To learn more about creating a compensation model please, see Creating a compensation model
In a remuneration audit, companies are required to identify any gender-based inequalities and make plans to address them by closing the pay gap. In addition to creating a compensation model and measuring the pay gap, you can have the system suggest raises targeted to specific employees in order to reduce or close the pay gap. To learn more, see Getting suggested remediation actions
Lastly, understanding workforce diversity is key to creating equality plans to meet the following requirements:
report with the results of a comprehensive analysis of equality and inequality within the company,
results of a remuneration audit,
plan for eliminating workplace discrimination, with specific steps and how they will be accomplished (including who is responsible and the planned timeline). In order to create an equality plan for eliminating workplace discrimination you may want to check out our Workforce Analytics feature and how it helps to understand your organization’s changing workforce. To learn more, see Workforce analytics.
Conclusion and next steps
If you would like further support around the remuneration register requirements in Spain, please don't hesitate to reach out for assistance through the Help Center support channel or reach out to our pay equity consultants at clientservicespe@beqom.com.