Pay equality has moved beyond being a matter of corporate responsibility alone to become a legal obligation affecting virtually all organisations in Spain.
Since the pay equality regulatory framework came into force, companies must maintain an updated pay register that demonstrates the transparency of their pay policies and facilitates the detection of potential gender-based pay discrimination.
However, many organisations still do not know how to prepare this document correctly, what information it must include or what risks they face if they fail to keep it up to date.
The reality is that the pay register has become one of the documents most frequently requested during labour inspections and regulatory compliance audits.
Having a correctly prepared remuneration register therefore not only ensures legal compliance, but also reduces legal risks, improves internal transparency and strengthens people management policies.
What is the pay register?
The pay register, also known as the remuneration register, is a mandatory document that compiles detailed information on the remuneration received by the workforce.
Its purpose is to guarantee the principle of equal treatment and remuneration between women and men for work of equal value.
To this end, the register must reflect:
- Base salary.
- Salary supplements.
- Non-salary payments.
- Total annual remuneration.
The information must be presented distinguishing between women and men, grouping employees according to consistent criteria that allow objective comparisons.
Who is required to maintain a pay register?
The pay register obligation applies to all companies, regardless of size, turnover, sector of activity or number of employees.
Both a five-person company and an organisation with hundreds of employees must hold this document.
There is no minimum workforce threshold that exempts a company from this obligation.
Legal framework for the pay register
The obligation is based primarily on:
- The Workers’ Statute.
- Royal Decree 902/2020 on pay equality between women and men.
- Royal Decree 901/2020 on equality plans.
What is the pay register used for?
When used properly, it can become a very valuable management tool.
It enables detection of potential pay gaps, identification of internal inequalities, improved organisational transparency, preparation for labour inspections, facilitation of equality audits, support for remuneration decisions, reduction of legal risks and strengthening of employment compliance.
Gender pay gap within a company: how to detect it correctly
Not every pay difference constitutes discrimination.
Differences may be justified by objective factors such as seniority, qualifications, experience, responsibility, technical specialisation, proven performance or commercial variables.
The problem arises when significant differences exist without objective and documented justification.
How to prepare a pay register step by step
- Identify the workforce (permanent, temporary, full-time and part-time employees).
- Collect salary data (base salary, supplements, incentives, bonuses, variable pay, allowances).
- Classify roles by professional group, professional category or positions of equal value.
- Calculate averages and medians to compare remuneration by gender.
- Analyse differences: origin, magnitude and justification.
- Document findings and retain all documentation.
Pay register and pay audit: key differences
The pay register is mandatory for all companies. Its purpose is to reflect the remuneration reality.
The pay audit forms part of equality plans and has a much broader scope: it analyses the remuneration structure, job evaluation, discrimination risks, promotion processes and pay policies.
Pay compliance: a new priority for companies
Pay compliance means establishing mechanisms to demonstrate that pay decisions are made following objective and transparent criteria.
A robust system reduces legal risks, facilitates inspections, improves decision traceability, strengthens corporate culture and increases internal trust.
What penalties can a company face?
The absence of a pay register or its incorrect preparation can lead to Labour Inspectorate requirements, infringement notices, financial penalties, employment claims and reputational risks.
How can GM Integra help you?
At GM Integra we help companies implement employment compliance systems tailored to current regulations.
Our team can help you prepare your pay register, review existing registers, identify pay gap risks, conduct pay audits, implement pay compliance measures, prepare documentation for inspections and integrate the register into a global employment management and HR strategy.
Do you need help implementing your pay register?
If you do not yet have a pay register or want to ensure it meets current legal requirements, we can help.
We analyse your company’s situation, review available documentation and support you throughout the implementation and update process.
Contact GM Integra and receive specialist advice on preparing your pay register, identifying pay gap risks and strengthening your organisation’s remuneration compliance.