Pay transparency checklist for employers

1. Step 1 Take stock of roles and pay

   • List every role with the people in it and their full pay: basic wage plus premiums, bonuses and benefits in kind.
   • Group roles that are the same work or work of equal value into categories of workers.
   • Note for each role the joint committee, the job class and the applicable pay scale.

   Based on: Directive, art. 3(1)(a) and (h), and art. 4

   Done on: ____________

2. Step 2 Set down objective criteria

   • Describe for each category which criteria the pay rests on: skills, effort, responsibility and working conditions.
   • Check that your job evaluation makes no distinction in the choice or weighting of criteria or in the conversion into pay.
   • Write down how someone progresses in pay or pay class, so you can show it to workers.

   Based on: Directive, art. 4(4) and art. 6; collective agreement no. 25, art. 3

   Done on: ____________

3. Step 3 Put a pay range in every vacancy

   • Set the starting pay or range for each open role based on the criteria from step 2.
   • Mention the collective agreement provisions that apply to the role, such as shift work premiums.
   • Make job titles and job ad texts gender-neutral.

   Based on: Directive, art. 5(1) and (3)

   Done on: ____________

4. Step 4 Review application forms and interviews

   • Remove the field for current or previous pay from online forms and from your recruitment software.
   • Delete the question from your interview guide and tell whoever selects on your behalf, such as a recruitment agency.
   • Check that job offers and selection criteria make no distinction between women and men.

   Based on: Directive, art. 5(2); gender act, art. 6(2)

   Done on: ____________

5. Step 5 Inform your workers

   • Make the criteria for pay and pay progression easy to access, for example on the intranet or in the work rules.
   • Agree who answers a written request on pay levels and how you reply within two months.
   • Schedule the yearly notice to all workers about their right to information.
   • Look for clauses in your employment contracts that forbid workers to disclose their pay.

   Based on: Directive, art. 6(1) and art. 7(3) to (5)

   Done on: ____________

6. Step 6 Prepare reporting according to your company size

   • Count your workers. From 250: first report by 7 June 2027 on 2026, then every year. From 150 to 249: also by 7 June 2027, then every three years. From 100 to 149: by 7 June 2031, then every three years.
   • Make sure you can split your pay data by sex, by quartile and by category, also for variable components.
   • Justify every difference of 5 percent or more in a category with objective criteria or remove it within six months; otherwise a joint pay assessment follows.
   • From 50 workers the Belgian two-yearly analysis of the pay structure simply continues to apply.

   Based on: Directive, art. 9 and 10; act of 22 April 2012

   Done on: ____________

7. Step 7 Follow the Belgian transposition

   • Check whether a bill or a new version of collective agreement no. 25 or no. 38 has appeared; on 12 November 2026 a first preliminary draft is under discussion in the cabinets.
   • Adjust thresholds, deadlines and penalties as soon as the Belgian text sets them.

   Based on: Directive, art. 34; federal parliament, plenary of 1 October 2026

   Done on: ____________

Sources for this data: see the list at the bottom.