The pay transparency register is a legal requirement for all companies in Spain. Many organizations look for a pay transparency register example to better understand how to prepare this document and comply with current regulations on pay equality.
This obligation is regulated by Real Decreto 902/2020 de igualdad retributiva entre mujeres y hombres, which requires companies to record employee salary information to guarantee the principle of equal pay for work of equal value.
To support companies, the Spanish Ministry of Equality and the Ministry of Labour have developed the official IR! tool for the pay transparency register, which includes templates and methodological guidance.
In this article we explain how a pay register should be structured and provide practical examples based on official models.
What is the pay transparency register and what does the regulation require?
The pay transparency register is a document that collects information about the average remuneration of employees, broken down by gender.
Its purpose is to guarantee salary transparency and detect potential pay inequalities within a company.
According to the regulation, the pay register must include:
- base salary
- salary supplements
- non-salary compensation
- arithmetic mean of remuneration
- salary median
In addition, the information must be broken down by gender and by professional groups or equivalent job positions.
As established in artículo 28 del Estatuto de los Trabajadores, men and women have the right to receive equal pay for work of equal value.
How the pay transparency register is structured
The pay register is usually organized through a table that groups salary information by job category or position.
The most common elements include:
- professional group or position
- number of employees
- average base salary
- salary supplements
- non-salary compensation
- total remuneration
This structure makes it easier to compare remuneration between women and men.
Below are two examples of pay transparency registers based on official templates.
Example 1 of a pay transparency register without a gender pay gap
This first example reflects a situation of pay equality, where men and women in equivalent positions receive the same remuneration.
| Professional Group | Gender | Average Base Salary (€) | Supplements (€) | Non-salary compensation (€) | Total (€) |
| Administration | Female | 22,000 | 2,500 | 500 | 25,000 |
| Administration | Male | 22,000 | 2,500 | 500 | 25,000 |
| Technician | Female | 30,000 | 3,000 | 700 | 33,700 |
| Technician | Male | 30,000 | 3,000 | 700 | 33,700 |
This example shows how the pay transparency register can help confirm that a company’s pay policy is fair and equal.
Example 2 of a pay transparency register with justified differences
In some cases, salary differences may exist between employees due to objective criteria such as job responsibilities, experience or performance incentives.
| Position | Gender | Average Base Salary (€) | Supplements (€) | Non-salary compensation (€) | Total (€) |
| Marketing technician | Female | 28,000 | 2,000 | 600 | 30,600 |
| Marketing manager | Male | 32,000 | 3,000 | 800 | 35,800 |
| Junior sales representative | Female | 26,000 | 3,000 | 500 | 29,500 |
| Senior sales representative | Male | 30,000 | 4,500 | 500 | 35,000 |
In this case, salary differences can be explained by factors such as seniority, responsibilities or performance-based incentives.
The regulation states that if the pay difference exceeds 25%, the company must provide a documented justification.
Common mistakes when preparing the pay transparency register
Although the pay register is mandatory, many companies make mistakes when preparing it.
Some of the most common include:
Not including all salary components
The register must include base salary, salary supplements and non-salary compensation.
Incorrectly grouping job positions
Companies must compare jobs of equal value, not simply similar job titles.
Not updating the register
The pay register must be reviewed at least once a year or whenever salary conditions change.
Not analysing the results
The pay register should not only be an administrative document but also a tool for identifying pay inequalities.
Benefits of properly preparing the pay transparency register
Having a well-prepared pay register offers several advantages for companies:
- improves salary transparency
- helps identify potential gender pay gaps
- reduces the risk of labour sanctions
- improves human resources management
- strengthens commitment to gender equality
According to data from Instituto Nacional de Estadística (INE), the gender pay gap remains one of the challenges in workplace equality, highlighting the importance of tools such as the pay transparency register.
Pay audit and salary register
In addition to the pay register, companies required to have an equality plan must also carry out a pay audit, as established in Real Decreto.
Companies that already had equality plans in force on 14 April 2021 were required to adapt their pay audits to this regulation before 14 January 2022.
In the case of groups of companies, the pay audit must be conducted independently for each company, as salary structures may differ.
The regulation does not impose a single job evaluation model. Companies may use analytical systems that guarantee pay equality.
Frequently asked questions about the pay transparency register
- Do all companies need a pay transparency register?
Yes. The regulation requires all companies, regardless of the number of employees, to have a pay register.
- How often must it be updated?
The pay transparency register must be updated at least once a year.
- Is it the same as a pay audit?
No. The pay register is mandatory for all companies, while a pay audit is only mandatory for companies that must implement an equality plan.
- Who can access the pay transparency register?
Employee representatives can access the full register. In companies without employee representation, workers may request information about gender pay differences.
How GM Integra can help you with the pay transparency register
Preparing the pay register can be complex, especially in companies with multiple job categories or variable compensation systems.
At GM Integra, we help companies comply with labour and equality regulations through specialized advice in labour management and human resources.
Our team can help you prepare the pay transparency register, analyse potential pay gaps and implement the necessary measures within the company’s equality plan.
We also provide legal labour advisory services to ensure that your company complies with all labour obligations and avoids potential sanctions.