Complying with the EBA Gender Pay Gap Data reporting

The principle of equal pay is fundamental to ethical remuneration practices. The European Union and other European institutions have reinforced this commitment through key legislation, such as the EU Pay Transparency Directive and the Treaty on the Functioning of the European Union (TFEU), which mandate equal pay for equal work or for work of equal value.

As a complement to these regulations, the European Banking Authority (EBA) published its final report, Guidelines on benchmarking exercises on remuneration practices, the gender pay gap, and approved higher ratios under Directive 2013/36/EU, in June 2022. The EBA gender pay gap guidelines further embody the principles of Article 157 TFEU regarding equal pay without gender discrimination.

The Guidelines outline the specific methodologies and benchmark data that covered financial institutions must collect and report to national competent authorities (NCAs), which then submit aggregated data to the EBA.

In this article, we break down the EBA Gender Pay Gap Data reporting framework and help you answer four key questions:

1. Who does it apply to?

2. What are the specific requirements for pay equity?

3. How does PayAnalytics help you meet these requirements?

4. Which steps should you take next?

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While this series in our Help Center highlights how you can use the PayAnalytics platform to fulfill various local pay equity reporting requirements, our documentation does not constitute legal advice.

1. Who does it apply to?

The European Banking Authority (EBA) has established guidelines for Gender Pay Gap (GPG) reporting that apply to specific financial institutions within the European Union. The applicability criteria cover:

• Credit Institutions and Investment Firms: Financial institutions subject to Directive 2013/36/EU (CRD IV / CRD V) and Regulation (EU) 2019/2033 (IFR).

• Significant Institutions: Institutions identified as significant by National Competent Authorities (NCAs) or the European Central Bank (ECB) based on size, internal organization, and the nature, scope, and complexity of their activities.

• Staff Categories: The reporting requirements apply to all staff members within covered institutions, with specific breakdown disclosures required for:

  • Identified Staff (Material Risk Takers / MRTs)

  • Members of the management body (in its supervisory and management functions)

  • Non-identified staff / general workforce

2. What is the requirement?

Under the EBA Guidelines, covered institutions are required to collect, analyze, and report gender pay gap metrics using standardized metrics across specified employee categories.

Specifically, employers must:

• Calculate the Raw Gender Pay Gap: Measure the unadjusted difference between the average (mean) and median remuneration of female and male employees across the entire organization.

• Disaggregate Pay Components: Separate reporting between fixed remuneration (base salary, fixed allowances) and variable remuneration (bonuses, performance awards, discretionary payments).

• Break Down Data by Staff Categories: Calculate gender pay gap metrics separately for members of the management body, Material Risk Takers (MRTs), and other staff tiers.

• Assess Pay Disparities: Evaluate whether identified pay gaps are justifiable based on objective, gender-neutral factors such as experience, role complexity, performance, or education.

• Remediate Unjustified Discrepancies: Take corrective action if gender-based pay gaps are found that cannot be justified by objective factors.

• Submit Reports to Competent Authorities: Provide the required data submissions annually or biennially (as mandated by national regulators) to document compliance and demonstrate steps taken to address disparities.

3. How does PayAnalytics help you to meet the requirement?

PayAnalytics streamlines the data preparation, calculation, and reporting steps needed to achieve compliance with EBA standards.

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Note that a dataset containing at least the following data needs to be imported prior to generating the report:

Preparing your dataset

A dataset containing at least the following fields must be imported prior to generating the report:

• Unique employee ID: Mandatory for all datasets.

• Gender: Defined for reporting purposes as either male or female (as specified in current reporting structures).

• Hourly pay: Computed as total fixed salary (including basic pay, fixed allowances, shift pay, piecework, holiday pay, and overtime, but excluding expense reimbursements, benefits in kind, redundancy pay, arrears, and employer pension contributions) divided by the total number of hours worked.

• Bonus remuneration: The pro-rated amount of variable pay received by employees within the reference period (set to 0 if no bonus was received).

• Benefits in kind: Two fields: one indicating whether an employee received a non-cash benefit in the reference period, and another indicating the pro-rated value (if applicable).

• Temporary worker indicator: A flag indicating whether an employee has a temporary contract.

• Part-time worker indicator: A flag indicating whether an employee works part-time or full-time. (Specific FTE level—e.g., 0.8 FTE—is not required here, as hours worked are accounted for in the hourly pay computation).

Generating the report

Creating an EBA-compliant report requires only a few steps within PayAnalytics:

1. Navigate to Reports: Go to the Reports section in the main navigation menu and select your dataset.

2. Next, click on Create new report button and select Gender Pay Gap data (EBA) configuration preset from the list of Built-in templates. This automatically configures:

   1. Mean and median pay gap metrics for fixed and variable remuneration.

   2. Disaggregation by employee categories (e.g., MRTs vs. non-MRTs).

   3. Objective factor mapping for adjusted gap evaluations.

3. Review & Justify: Evaluate identified disparities within the interface to determine if pay differences correlate with objective criteria (e.g., tenure, performance, or job grade).

4. Export Findings: Export your finalized analysis to Word, Excel, or PDF formats for internal governance committees or regulatory submission to your NCA.

4. Which steps should you take next?

Once your initial report has been generated in PayAnalytics > Reports, complete the following operational steps to ensure full compliance:

• Evaluate Unjustified Gaps: Review categories showing unexplained pay disparities and conduct targeted internal pay equity audits.

• Establish Remediation Plans: Define clear timelines and budget allocations for salary adjustments where gaps cannot be objectively justified.

• Engage Internal Stakeholders: Share findings with your Remuneration Committee, HR leadership, and worker representatives (where applicable) to align on compensation policies.

• Submit Regulatory Disclosures: Ensure all completed disclosures are filed with your respective National Competent Authority within specified regulatory deadlines.

• Establish Regular Monitoring: Set up recurring data audits to track pay gap trends over time and ensure ongoing compliance with upcoming regulatory updates.

Conclusion and next steps

Understanding workforce diversity is key to understanding why a raw (unadjusted) pay gap might exist. You may want to check out our Workforce Analytics report to learn how it helps explain your organization’s changing workforce. Refer to theWorkforce analytics article in our Help Center to learn more.