Introduction
Note: As of January 2026, Spain has not yet published draft legislation to transpose the EU Pay Transparency Directive (EUPTD). However, all EU Member States — including Spain — are required to adopt the Directive’s provisions by June 7, 2026. Track the latest EU Member State transposition developments with our monitor.
Spanish laws on equal pay are among the most comprehensive in Europe. In 2020, the Spanish government introduced two complementary Royal Decrees aimed at addressing gender equality. Decree 901/2020 regulates gender equality plans, and Decree 902/2020 targets pay discrimination based on gender. Both decrees seek to ensure equal treatment of, and opportunities for, employees.
Every Spanish company, regardless of size, must maintain a salary register, categorized by profession and gender. Employers with 50 or more employees must also create a job evaluation system, carry out a remuneration audit, and create an equality plan. Gender pay gaps of 25% or more must be justified.
The Royal Decrees came into force on Jan. 14, 2021, and April 14, 2021, respectively.
Spain reporting requirements
Who needs to report?
All employers must complete a remuneration register. Employers with 50 or more employees must perform a job evaluation, remuneration audit and Equality Plan.
What to report?
Royal Decree 902/2020 establishes four key components for pay transparency:
Remuneration register: Every company is required to prepare a register, including aggregated and disaggregated pay data. All employees are to be included, including executives, senior managers, part-time employees, and people on fixed-terms contracts that have been in place for six months. The register must include average and median pay broken down by gender, base pay and compensation (including bonuses and additional benefits), and professional classification groups. Remuneration registers must be reviewed annually.
Job evaluation system: Job evaluations are intended to establish equal pay for work of equal value and are used in the remuneration audit and the remuneration register. Employers must ensure job classifications do not contribute to discrimination. Job evaluations are obligatory for companies with 50 or more employees.
Remuneration audit:The remuneration audit’s purpose is to obtain the necessary info to verify whether the company’s remuneration system complies with the effective application of the principle of equal pay for work of equal value, and identify any adjusted pay gaps. It must also include an action plan that explains how the employer will close such identified gaps. The audit shall be valid for the duration of the equality plan unless a shorter period is determined. Note, per government issued guidance, the remuneration register and job evaluation are prerequisites to a remuneration audit. Remuneration audits are required for every organization with 50 or more employees.
Equality plan: Employers with 50 or more workers, or if the company is required to do so per a collective bargaining agreement, or due to ancillary sanctions, must create and publicly register an equality plan. An equality plan is a set of specific measures to ensure equal treatment of and equal opportunities for men and women. It must incorporate, among other measures, the results of the company’s remuneration audit.
Equality plans must comply with Chapter 3 of Royal Decree 901/2020, covering the following:
- Selection and recruitment process.
- Professional classification.
- Training.
- Career advancement.
- Working conditions, including the salary audit between women and men in accordance with the provisions of Royal Decree 902/2020, on equal pay between women and men.
- Co-responsible exercise of the rights of personal, family and working life.
- Under-representation of women.
- Remuneration
- Prevention of sexual and gender-based harassment.
Equality Plans are aimed at achieving equal treatment and opportunities for women and men and eliminating discrimination on the grounds of gender. The results of the company’s remuneration audit should be included in the plan. Plans are to be negotiated with workers’ representatives or labor unions.
After a maximum of four years, a new equality plan is required. Appendix of Royal Decree 901/2020 provides employers with guidance on what to consider in the preparation of an Equality Plan.
Where and when to report?
Relevant employers must report on the above mentioned requirements as follow:
Regulatory filing
- Equality Plans must be submitted to the public register, and will be published in the equality section of the website of the Ministry of Finance and Public Function. Royal Decree 713/2010 requires registration to be mediated through the Register of Collective Bargaining Agreements and Collective Labor Agreements.
- The remuneration register does not need to be filed to the governing body or publicly, but employers are obligated to store and make readily available for inspection
Internal disclosure
- All employees will be entitled to access the register through workers’ representatives, or if none, then have direct access, but the information will be limited to the statistical analysis – the average pay percentage differences between men and women. In other words, individual level pay data will not be accessible.
- Royal Decree 713/2010 requires registration to be mediated through the Register of Collective Bargaining Agreements and Collective Labor Agreements.
Deadlines and cadence Remuneration registers must be conducted annually. Employers subject to the job evaluation, remuneration audit, and equality plan must report 4 after becoming subject to the act.
Spain pay transparency requirements
Spanish employers are required to commit to the principle of pay transparency to ensure the effective application of the principles of equal treatment and the prevention of pay discrimination. The purpose of the salary register is to demonstrate that all employees in the same position and function are paid equally.
Employment equity standards
The principle of “equal pay for work of equal value” is binding on all companies, regardless of size or number of employees, and on all collective agreements. Decree 902/2020 defines equal work as follows:
“…when the nature of the functions or tasks effectively entrusted, the educational, professional or training conditions required for its exercise, the factors strictly related to its performance and the working conditions in which those activities are actually carried out are equivalent.”
The risks of non-compliance
Sanctions are punitive and among the highest in Europe. Breaches of equal treatment, including discriminatory pay between men and women, are considered a “very serious infringement”. If employer conduct constitutes a “serious” or “very serious infringement” potential financial penalties range from €626 to €187,515 (approximately US $683 – $204,679).
Additional sanctions may apply, including the loss of public benefits and bonuses for anywhere from six months to two years.
The Public Sector Contracts Law (Ley de Contratos del Sector Público) prohibits organizations from contracting with companies that fail to prepare an Equality Plan when required.
How can Trusaic assist with Spain gender equality plans & remuneration audit reporting compliance?
1. Comply – Use RAPTR™ to complete required reporting by compliance deadlines.
Stay ahead of evolving regulations with Trusaic’s Regulatory Pay Transparency Reporting™ solution, designed to help you determine applicability, meet deadlines, and submit compliant reports across EU jurisdictions with the click of a button.
Our Pay Equity Software Suite ensures your pay systems are legally defensible, gender-neutral, and future-proof — automating complex reporting and enabling GDPR-compliant data sharing through certified integrations with major HCM platforms.
2. Correct – Use PayParity® to understand, explain and resolve pay disparities.
Use PayParity to identify, explain, and resolve pay disparities across gender, race, age, and more. Whether you’re conducting proactive assessments or responding to compliance triggers like the EU Directive’s Joint Pay Assessment requirement, PayParity delivers defensible, data-driven insights. Our Remediation Optimization Spend Agent (R.O.S.A.) works as PayParity’s AI remediation partner to ensure you lower your pay gap below 5% while maximizing the ROI of your remediation budget.
3. Communicate – Use the Pay Equity Product Suite to communicate narratives and share salary ranges with confidence.
Comply confidently with the EU Directive’s pay range transparency mandates using Trusaic’s Salary Range Finder, which provides data-driven guidance for equitable pay ranges that can be shared with candidates and employees.
Our Pay Transparency Agent answers reporting questions instantly, and our Communications Agent crafts context-specific narratives — in any language — to support your public disclosures and internal communications.
How to prepare to comply with the EU Directive
The EU Pay Transparency Directive was approved in 2023, establishing a clear framework for EU member states to apply the principle of equal pay for equal work or work of equal value.
EU member states have three years from June 7, 2023 to transpose the directive into law. Likely implementation dates are 2026, however, some countries may enact legislation earlier. All 27 member states are required to adopt the directive.
Employers operating in EU member states can take several preliminary steps to ensure compliance with the upcoming legislation. The EU Directive includes a requirement for a Joint Pay Assessment where pay gaps are higher than 5%, compared to Spain’s existing legislation which requires companies to act only if the pay gap is 25% or higher.
Trusaic is GDPR compliant and can assist any organization in any EU state in meeting its obligations under both the EU Corporate Sustainability Reporting Directive and the EU Pay Transparency Directive.