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Pay gap: calculating the pay transparency indicators

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Calculate my company’s pay gap

Employers with 150 or more employees will have to report their gender pay gap by 7 June 2027 at the latest, those with 100 to 149 employees by 7 June 2031 at the latest, under Directive (EU) 2023/970. An unjustified average gap of at least 5% in a category of workers triggers a joint pay assessment.

In Belgium, the transposing law has not yet been adopted, according to sources as of 17 September 2026. The tool already calculates the directive’s seven indicators, in your browser: no pay data leaves your computer.

Calculate my company’s pay gap

Import an anonymised CSV file (one line per employee, no names) or paste a few lines. The lines shown at the start are a fictitious example. The file is read in your browser: nothing is sent or kept.

The tool could not be displayed. Reload the page (Cmd + Shift + R on a Mac, Ctrl + F5 on a PC).

250+employees: a report every year, the first by 7 June 2027 at the latest
150 to 249employees: a report every three years, from 7 June 2027
100 to 149employees: a report every three years, from 7 June 2031
5%average gap in a category, unjustified: joint pay assessment

The seven indicators of Article 9

The directive defines the pay gap as the difference between men’s and women’s average pay, as a percentage of men’s. Pay includes the base salary and all other benefits, in cash or in kind; it is measured per year and per hour.

IndicatorWhat Indexo calculates
a. Mean pay gapOn hourly pay and on annual pay
b. Mean gap in complementary or variable componentsAmong recipients only, and across all staff
c. Median pay gapOn hourly pay and on annual pay
d. Median gap in complementary or variable componentsAmong recipients
e. Proportion of women and men receiving these componentsAs a percentage of each group
f. Proportion of women and men in each quartileHourly pay quartiles
g. Gap by category of workers, base salary and variable componentsGap in base salary, variable part and total, with the 5% threshold
Indicators to be reported (Article 9, paragraph 1, of Directive (EU) 2023/970) and what the tool calculates.

Who must report, and when?

Employer’s headcountFirst reportAfter that
250 or more employees7 June 2027Every year
From 150 to 249 employees7 June 2027Every three years
From 100 to 149 employees7 June 2031Every three years
Fewer than 100 employeesVoluntary, unless Belgian law requires it—
Directive timetable (Article 9, paragraphs 2 to 5). Reports cover the previous calendar year.

These are the directive’s dates. The Belgian law will specify to whom the report is submitted and how it is published. In the meantime, the Act of 22 April 2012 on the pay gap still applies: from an average of 50 employees, a report analysing the pay structure is drawn up every two years and submitted to the works council.

Above 5%: the joint pay assessment

The employer must carry out a joint pay assessment with the workers’ representatives when three conditions are met (Article 10):

  • the report shows an average pay gap of at least 5% in a category of workers;
  • the employer does not justify the gap on objective, gender-neutral criteria;
  • the employer has not remedied it within 6 months of reporting the data.

A category of workers groups, in a non-arbitrary way, the people doing the same work or work of equal value. In a small category, a gap can come down to a single person’s pay: the tool flags the threshold, but what matters is analysing the reasons.

Where does Belgian transposition stand? (sources as of 17 September 2026)

The European transposition deadline was 7 June 2026. Belgium did not meet it, and this legal deadline remains unchanged: on 1 June 2026, the federal government merely asked the European Commission not to open infringement proceedings for six months.

For the private sector, the new obligations (report, information before hiring, joint pay assessment) depend on Belgian law. The FEB (Federation of Belgian Enterprises) does, however, point to legal uncertainty: the directive is based on Article 21 of the Charter of Fundamental Rights of the European Union, and a court could take this into account before transposition. The principle of equal pay for women and men already applies (Article 157 of the Treaty on the Functioning of the European Union, CLA No. 25).

Level of governmentStatusSources
Federal (private sector)No law published according to the sources read (as of 17 September 2026). Baker McKenzie (16 September 2026): a first preliminary draft has been prepared with the social partners but not tabled; the legislator is waiting for clarification from the European Commission. Simmons & Simmons (17 September 2026): text still awaited, timetable unknown. L&E Global (30 June 2026): National Labour Council opinion not finalised, transposition expected at the end of 2026 or early 2027.Baker McKenzie, Simmons & Simmons, L&E Global
Wallonia-Brussels Federation (its own staff)Transposed by decree according to Securex (9 June 2026), Partena (22 April 2026) and L&E Global (30 June 2026). Preliminary draft adopted by the government on 9 November 2023 (RTBF). Date and reference of the decree: not read.Securex, Partena, L&E Global, RTBF
Flanders (its own staff)Conflicting sources: preliminary draft decree ready (Securex, 9 June 2026; Partena, 22 April 2026) or transposed for staff of the Flemish authorities (L&E Global, 30 June 2026).Securex, Partena, L&E Global
Other entities (their own staff)No information read. Simmons & Simmons (17 September 2026): some regional authorities have adopted measures for their public employers.Simmons & Simmons
Status of the transposition of Directive (EU) 2023/970 in Belgium, based on secondary sources dated from June to 17 September 2026. To be checked in the Belgian Official Gazette before any decision.

National Labour Council CLAs No. 25 (equal pay) and No. 38 (recruitment and selection) will also have to be revised. This page will be updated as soon as the law is published.

Example: the indicators for a fictitious file

The tool’s sample file has 24 made-up employees (11 women, 13 men), split into 3 categories. Here is what it gives:

IndicatorValue
Mean gap, hourly pay (a)13.6%
Mean gap, annual pay (a)17.4%
Median gap, hourly pay (c)10.0%
Mean gap in the variable part, among recipients (b)36.2%
Women receiving a variable part (e)63.6%
Men receiving a variable part (e)76.9%
Women in the highest-paid quartile (f)16.7%
Women in the lowest-paid quartile (f)66.7%
Indicators for all staff, fictitious file.
CategoryWomen / menBase salary (hourly)Total (hourly)5% threshold
Level 1 - Support roles4 / 42.7%3.8%Not reached
Level 2 - Technical roles4 / 45.8%7.2%Reached
Level 3 - Management3 / 58.1%9.7%Reached
Gap by category (g), fictitious file. A positive gap: men are better paid on average.

Two categories out of three reach the 5% threshold: Level 2 - Technical roles, Level 3 - Management. The annual gap (17.4%) is larger than the hourly gap (13.6%): three women work part-time in this example. That is why the tool calculates both.

Preparing the CSV file

One line per employee, with no name or national register number. Export it from your payroll software or a spreadsheet, in CSV format, with a semicolon or comma as separator. The tool offers a blank template to download.

ColumnContentsExample
categorieCategory of workers: same work or work of equal valueLevel 2
genreF for a woman, H for a man; any other entry is counted in the headcount, not in the gapsF
remuneration_fixeGross fixed pay, annual or hourly (chosen in the tool)41000
part_variableGross complementary or variable components for the year (allowances, bonuses…), 0 if none1500
temps_de_travailFraction of full-time, hours a week or hours paid over the year (chosen in the tool)0.8
File columns (the first line may contain headings).

The calculation method

  • Mean or median gap: (men’s value − women’s value) ÷ men’s value. The median is the middle value; with an even number of people, the average of the two middle values.
  • Hourly pay: annual pay, fixed and variable, divided by the year’s working hours (e.g. fraction × full-time hours × 52).
  • Quartiles: employees are ranked by hourly pay from lowest to highest, then split into four groups of equal size, give or take one person.
  • Variable part: the directive does not say whether the gap is calculated among recipients only; the tool gives both readings.

These choices follow the directive’s definitions where it is precise. The exact arrangements (hours counted, components, receiving body) will be set by Belgian law: the tool will be adapted when it is published. Indicative information, not legal advice.

Salary ranges, with their net pay

For each category, the tool gives the observed base salary range, as full-time gross monthly pay, and its estimated net pay for a single person. A link prepares the ‘estimated net’ badge to place below your job adverts: ‘Estimated net’ badge for recruiters.

Frequently asked questions

Does my company already have to publish its pay gap?

Not yet: in Belgium, the transposing law has not been adopted according to sources as of 17 September 2026. The first reports required by the directive are due by 7 June 2027 at the latest for employers with 150 or more employees. The Act of 22 April 2012 already requires, from 50 employees, an analysis report to the works council every two years.

How is the pay gap calculated?

It is the difference between men’s and women’s average pay, divided by men’s. If men earn €25 an hour on average and women €23, the gap is 2 ÷ 25 = 8%. The same calculation is done with the medians.

What happens if a category has a gap of more than 5%?

If the gap is not justified by objective, gender-neutral criteria and is not remedied within 6 months, the employer must carry out a joint pay assessment with the workers’ representatives (Article 10 of the directive).

Is my pay data sent to Indexo?

No. The file is read by your browser, on your computer. It is sent to no server and is not kept: closing the page erases everything. Use an anonymised file, with no names.

What next?

Sources

Parameters in force on 1 October 2026. Each parameter links to its source, the official one where it exists; a secondary source is flagged as such.