Germany's Federal Anti-Discrimination Agency updates tool for reviewing pay equality

At a glance

• The EG-Check consists of several instruments for reviewing pay equality, including the equal value check (GleichWertCheck) and the pay system check (Entgeltsystem-Check).
• The equal value check provides a discrimination-free analytical job evaluation method that makes different roles comparable through objective, gender-neutral criteria.
• The pay system check allows employers to verify whether their pay system or collective agreement complies with the requirements of the EU Pay Transparency Directive (Directive) through a structured questionnaire.
• The EG-Check is not a legislative act and does not constitute an interpretation of the Directive or national law.

The EG-Check is a tool developed by Germany's Federal Anti-Discrimination Agency that enables employers to examine existing pay structures for gender-based discrimination at establishment level. The tool has been fundamentally revised and adapted to the current requirements of the Directive.

Equal value check

The equal value check is an analytical job evaluation method for assessing whether different roles are of equal value. It evaluates activities according to the criteria set out in the Directive: Skills, effort, responsibility and working conditions. These criteria are further broken down into a total of 20 sub-categories. By assigning points to each criterion and sub-categories, it enables meaningful comparison between jobs on the basis of objective, gender-neutral factors.

Pay system check

The pay system check offers the possibility of verifying, through a structured questionnaire, whether the pay system applied by a company or under a collective agreement complies with the requirements of the Directive. The results of the analysis provide indications of any necessary adjustments to pay systems and structures. Similarly, concepts or proposals for planned pay systems can also be assessed for discrimination using the pay system check.

Key takeaways

The EG-Check is not a legislative act and does not constitute an interpretation of the Directive or national law.

The European Commission, together with the European Institute for Gender Equality, has presented EU-wide guidelines on gender-neutral job evaluation and classification. These constitute the primary source with regard to the Directive itself. In the absence of national implementation of the Directive in Germany, the EG-Check explicitly refers to the Directive. When it comes to national legislation, local courts may nevertheless tend to consider domestic tools. Employers in Germany would therefore be well advised to familiarise themselves with both instruments.