CRA’s Labor & Employment consultants were retained by a global financial institution to support its preparation for the upcoming pay reporting obligations under the EU Pay Transparency Directive (Directive (EU) 2023/970). The Directive seeks to operationalize the principle of equal pay for equal work, with the first mandatory pay-gap report, covering 2026 data, due by June 2027.
To help the client prepare, the Labor & Employment team conducted a separate gender-pay assessment for each EU country in which the firm operates. The work included an examination of gender representation across worker categories, analysis of average pay and variable compensation, calculations of both the overall and median gender pay gaps, and evaluation of the gender distribution across pay-quartile bands. The team also developed models to assess gender pay differences. A review of the completeness and consistency of key employee-level data and compensation variables was conducted to perform the analysis.
As one of its key deliverables, CRA provided the client with a deeper, more structured understanding of the readiness of their underlying data, as well as early, data‑driven insights into pay‑related patterns that may merit closer examination.
Overall, CRA’s work illustrates that compliance with the EU Pay Transparency Directive hinges on the ability to implement technically rigorous pay analyses, grounded in high-quality, standardized data that can then be systematically reviewed, validated, and governed by internal stakeholders.
