From April 14 Spanish companies are already required to keep a salary register with the average values ​​of the salaries received by their workforce disaggregated by sex and professional categories.

To facilitate its implementation, we tell you what this salary record consists of, what data it must include and we provide you with access to the IR tool! offered by the Ministry of Labor for its implementation.


What is the salary register?

The salary record will serve to collect information on gender pay in the different professional categories and allow the development of corrective measures to achieve workforce without gender inequalities.

The wage gap between men and women in Spain exceeded 20% in 2018 according to data from the National Institute of Statistics, which indicates that in that year the average gross salary of women was 78,6% compared to that of men.

To prevent these differences from occurring the Workers' Statute already includes in its article 28.2 the obligation of companies to keep a record of the average values ​​of salaries, with all concepts, distributed by sex and professional groups of equal or equal value.

In practice, this registry was not being carried out so, last October, its implementation was promoted through two regulations, RD 901 and 902/2020, which are intended to develop business obligations in matters of equal pay between men and women and registration and deposit of collective bargaining agreements and agreements in companies.

This new regulation includes how to evaluate jobs, how companies should keep track of wages and what penalties You may have the reflection of a wage inequality in your records.

A period of 6 months was set to adapt the salary records to the regulations, and now, as of April 14, it is mandatory.

These are them keys to keep in mind in relation to the salary register:

  • All companies, with at least one employee, are obliged to implement the salary register.
  • In the salary register you must include the entire staff, including management personnel, regardless of the type of contract or its seniority.
  • The updating of the information must be annual, unless there are substantial modifications that make it advisable to reflect them before this maximum limit.
  • Workers or, where appropriate, their legal representatives before the company, may have access to full content from the register.
  • If the salary record reflects a salary difference greater than 25%, the company must justify it in order to avoid gender discrimination and develop a plan of corrective measures.
  • Companies that do not comply with the requirements reflected in the regulations may be sanctioned with up to 250 €.


What data should the salary register contain?

As we have seen, the salary register must be updated annually and, both for its creation at the beginning and for subsequent modifications, companies must take into account the legal representatives of the workers.

The content that the salary record should reflect It is detailed in article 28.2 of the Workers' Statute, and, in summary, must contain the following data:

  • The mean values ​​of the salaries, including overtime or shifts, for example.
  • The average values ​​of salary supplements and extra-salary perceptions such as allowances or mileage.
  • The data must be disaggregated by sex.
  • This information will be provided for each professional group or category.


The Ministry of Labor has facilitated a tool for the implementation of the registry denominated salary Spanish tool for equal payKnown as TO GO! o Equal Pay, prepared with the consensus of the CEOE and unions, and that you can download through the link.

It is an Excel where we must go detailing for each worker the data related to seniority, job position and department to which they belong, hours and working hours, and of course the salary and all those extras and extra-salary payments.

We trust that this summary will facilitate the implementation of the salary register, but it is important to bear in mind that you can count on our Professional advice.

And you, what difficulties are you finding to start the salary register? We read you in the comments area.

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