Pay Audits in Spain: A Step-by-Step Guide to Royal Decree 902/2020

What a pay audit is

A pay audit is an in-depth diagnosis of a company's salary policy to detect and correct sex-based discrimination. It is governed by Royal Decree 902/2020 on equal pay between women and men, which develops the principle of equal pay for work of equal value in Article 28 of the Workers Statute. It should not be confused with the simple pay register: the audit goes further and requires analysing the causes of any differences.

When is it mandatory?

The pay audit is mandatory for every company that must have an equality plan, that is, those with 50 or more employees, as well as those required by their collective agreement or by the labour authority. It forms part of the equality plan itself and must be kept up to date while the plan is in force.

The pay register as a starting point

Every company, regardless of size, must keep a pay register with the average values of salaries, supplements and non-salary items, broken down by sex and distributed across professional groups, categories or jobs of equal value. This register is the raw material of the audit.

The register shows the snapshot; the audit explains why the difference exists and requires action if it is not justified.

Audit phases step by step

1. Diagnosis of the pay situation: evaluating jobs against objective criteria to identify work of equal value.
2. Gender gap analysis: calculating the average pay differences between women and men in each grouping.
3. Identifying causes: determining whether the differences respond to objective factors or to discrimination.
4. Action plan: corrective measures, deadlines, responsibilities and a monitoring system.

How to analyse the pay gap

Royal Decree 902/2020 sets a relevant threshold: if the average pay of one sex is 25% or more higher than the other within the same group, the company must objectively justify that difference or it will be presumed discriminatory. The analysis must consider total pay, not only base salary.

Connection with the equality plan

The audit is not a standalone document: it is embedded in the equality plan, and its conclusions feed the equal-pay measures. Keeping the register, the audit and the plan consistent is essential to pass an inspection.

With RegulaKit you centralise the pay and working-time data that feed the register and ease the audit. To estimate the cost of non-compliance, try our penalty calculator.