Spreadsheet, tool or consultant: how to prepare for EU pay transparency
For most small and mid-sized employers, the work under Directive (EU) 2023/970 is a calculation plus a few standard texts. A spreadsheet can do it if you have the time, a tool does it faster, and a consultant or law firm is the right choice when the legal questions are harder than the numbers. Here is an honest comparison.
What you are preparing for
Three recurring tasks: pay information for applicants before the interview (Article 5), written answers to worker pay requests within at most two months (Article 7), and for employers with 100 or more workers a gender pay gap report, first due by 7 June 2027 or 7 June 2031 depending on headcount (Article 9) [1][2][3]. A category gap of 5% or more that is not justified or fixed within six months leads to a joint pay assessment (Article 10) [1][4].
Side by side
| Spreadsheet | Pay Transparency Kit | Consultant or law firm | |
|---|---|---|---|
| Cost | Your own time | $129 one-time | Hourly or project fee; ask for a quote |
| Time to first report | Days, if you build formulas from scratch | An afternoon, once your CSV is clean | Weeks, depending on their schedule |
| Data privacy | Stays with you, but files get emailed around | Stays in your browser, no upload | You share payroll data under a contract |
| Calculation errors | Higher: formulas break quietly | Lower: fixed method, tested | Low, and someone else checks |
| Legal judgment | None | None | Yes |
| National rules | You check them | You check them | They check them |
| Joint pay assessment support | No | Flags categories at 5% or more | Yes, including talks with representatives |
Spreadsheet
A spreadsheet works. The indicators are averages, medians, proportions and quartiles, all standard functions. It costs nothing extra and you control the file.
The risks are practical. Median and quartile formulas are easy to get subtly wrong, for example by sorting one column and not the others. Hourly pay for part-time workers needs a consistent method. Each answer to a worker request means filtering the data again. And payroll files tend to end up in inboxes and shared drives.
Right choice when: you have under 100 workers, few categories, someone comfortable with formulas, and time to build and test the sheet.
A dedicated tool
Pay Transparency Kit is one offline HTML file. You open your payroll CSV, and it calculates the Article 9 indicators, flags categories at 5% or more, drafts the pay range text for job ads and drafts answers to pay requests with the due date. Nothing leaves your computer.
What it does not do: it does not give legal advice, it does not decide whether a gap is justified, and it does not know every national variation. Countries had to transpose the directive by 7 June 2026 and some differ in details [5][6]. You still check your own country's rules and forms.
Right choice when: you want correct numbers quickly, keep payroll data in-house, and your questions are mainly "what are the figures" rather than "what does the law require of us here".
Consultant or law firm
A good adviser brings what no spreadsheet or tool can: judgment. They can tell you whether your categories of workers hold up, whether a gap has an objective, gender-neutral explanation, how your national law differs from the directive, and how to run a joint pay assessment with worker representatives.
The costs are higher and you share sensitive data with an outside party, under a contract. For a straightforward report, you may pay expert rates for a calculation.
Right choice when: a category shows a gap of 5% or more that you cannot clearly explain; you expect a joint pay assessment; you operate in several countries with different national rules; you face a dispute or claim; or your pay structure is complex, with many allowances or collective agreements. In these cases, a consultant is the better choice, not an optional extra.
A sensible combination
Many employers do the routine part themselves and pay for advice only where judgment is needed. Calculate the indicators yourself, with a spreadsheet or a tool. If every category is well under 5% and your categories are clear, you may need little outside help. If a category is close to or above 5%, bring in an adviser with the numbers already prepared. Their time then goes into the question that matters, not into data cleaning.
Related guides
- Gender pay gap report template
- Salary ranges in job ads under the EU Pay Transparency Directive
- How to answer an employee pay information request
Sources
- Directive (EU) 2023/970, Articles 5, 7, 9 and 10 (EUR-Lex)
- Addleshaw Goddard, EU Pay Transparency Directive: the requirements (reporting thresholds and dates)
- Legalink, Summary of the EU Equal Pay and Pay Transparency Directive (Article 7)
- Mondaq, Pay Transparency Directive: what is a joint pay assessment
- Clifford Chance, Pay transparency directive (transposition date 7 June 2026)
- Lockton, Poland to implement pre-employment requirements of the EU Pay Transparency Directive
This guide explains the rules in plain language. It is not legal advice. Check your own country's law and, when in doubt, ask a qualified adviser.