Equal pay for equal work or work of equal value (pay transparency and enforcement mechanisms)
47 submissions from 44 organizations told the European Commission what they think about this file. Here is what each of them said, in their own words.
The Commission lists 628 submissions on this file. Shown here: the 47 from organizations. Not shown, by design: submissions from private individuals, which we never publish, and anything filed since our last weekly refresh.
Who showed up
17 submissions from industry — companies and their trade associations — against 19 from civil society: NGOs, consumer organizations, environmental groups and trade unions.
Industry 17Civil society 19Public authorities, academia, other 11
Groupings use the respondent type each organization selected when filing. Counting submissions, not organizations — a body that filed twice is counted twice.
What the room declares
27 of 44
in the EU Register
126
full-time lobbying staff
€12.9M+
declared costs a year
75
EP accreditations declared
Self-declared to the EU Transparency Register (snapshot 2 Sept 2026). The cost figure sums band floors, so the true total is higher.
The file, right now
The consultation closed on 6 Oct 2021 — it ran from 15 Apr 2021.
Femina Europa welcomes the action taken by the European Commission in its proposal for a Directive to “strengthen the application of the principle of equal pay for work of equal value or equal value between men and women through transparent pay and enforcement mechanisms.” Femina Europa has noted with interest Article 1 of the Commission proposal, which calls for “the prohibition of discrimination on grounds of sex…
Filed in French · English published by the European Commission
The proposal for a directive, which is part of the European Pillar of Social Rights, is seen as an attempt to effectively implement the right to equal treatment, specifically in the area of remuneration. We generally support this endeavour.
Filed in Czech · English published by the European Commission
Dear Sir/Madam, EWLA welcomes the European Commission's Proposal. For our detailed comment, please, see the attached statement of today. Regarding our size we have indicated our membership (not employees) as we are an umbrella organisation of women lawyers and women lawyers associations throughout Europe. Yours sincerely, [name removed] M.E.L.S. Attorney-at-law European Women Lawyers Association
The DFK — Association of Professional and Managers is largely in favour of the Commission’s proposal for a directive on pay transparency. Finally, there is a promising initiative to close the Gender Pay Gap. The proposal contains important elements that can finally make the German pay transparency law more effective.
Filed in German · English published by the European Commission
We appreciate the EC efforts in tackling the enforcement of the right to equal pay, but we have concerns that current proposals do not sufficiently reflect factual and legal reality, and may excessively overburden employers. The EC’s assumption of a gender pay gap in the EU of 14% seems excessive.
The Federation of Catholic Family Associations in Europe welcomes the Commission’s proposal for a directive to “strengthen the application of the principle of equal pay for equal work or work of equal value between men and women through pay transparency and enforcement mechanisms”.
Eumedion supports the proposal that requires companies with at least 250 workers to publish information on the gender pay gap. This follows from Eumedion’s statement with respect to the European Commission's proposal for a directive on pay transparency. In the proposed directive rules are introduced with the aim of combating inequality in pay between women and men.
Pay gap data is hard to calculate and hazardous to interpret. Different versions of the pay gap (between full-time workers, part-time workers, mean, median) will result in different answers and trends. The pay gap does not result from men and women doing the same job and being paid unequally. In the UK, there has been an Equal Pay Act since 1970 to prevent this.
The Danish Trade Union Confederation works at national and European level for reducing the gender-based pay gap by enforcing the principle of equal pay and the concept of “work of equal value”. Equal pay is a fundamental right, which should be promoted and guaranteed. The Danish labour market is characterised by a strong involvement of the social partners at company, local and national level.
The initial position of TCO on the European Commission proposal for a pay transparency directive General remarks • It is of crucial importance that a directive on pay transparency and strengthened enforcement mechanisms is designed in a well-balanced and proportionate way. The directive should not interfere with national labour market models or national systems for pay determination.
Summary of Unionen's* position on the Commission’s proposal for a Pay Transparency Directive Unionen believes that the proposed Pay Transparency Directive could, by promoting greater pay transparency, have a positive impact on gender equality in the workplace, by increasing the pressure on employers to carry out pay surveys and enforce equal pay between women and men for equal work of equal value.
JHL is Finland’s third largest trade union. Almost 200 000 members of the Union work in municipalities, the state, churches and private welfare services. JHL advocates pay transparency and sees greater pay transparency through EU-level legislation as an effective way to promote equal pay.
Filed in Finnish · English published by the European Commission
CPME, Confederation of Small and Medium-Sized Enterprises, defends the interests of French small and medium-sized enterprises in all sectors: Industry, services, commerce, crafts, liberal professions and the social and solidarity-based economy. As a social partner, the Confederation represents them both in the joint negotiations and with the public authorities, France and the European Union.
Filed in French · English published by the European Commission
From the point of view of employers in the German craft sector, there is no need for a directive to strengthen the application of the principle of equal pay for men and women through pay transparency and enforcement mechanisms.
Transport companies are concerned about developments in which the Commission is putting forward more and more detailed legislative proposals in the field of labour law. The proposals impose a significant administrative burden on businesses and violate the principles of subsidiarity and proportionality. It goes without saying that workers should receive equal pay for equal work.
Filed in Swedish · English published by the European Commission
Eurocadres welcomes the content of the pay transparency directive, which will increase access to information and tools to promote equal pay. Some reinforcements are still needed to close the gender pay gap. The principle of equal pay for work of equal value states that European Union member states are obliged to ensure precisely that this gap is eliminated.
The Luxembourg Chamber of Employees (CSL) welcomes the European Commission’s proposal for a Directive to strengthen the application of the principle of equal pay for men and women through pay transparency. Nevertheless, the CSL notes that certain measures provided for in the proposal for a Directive require particular attention, in particular as regards: • criteria for comparing the value of work; • transparency of…
Filed in French · English published by the European Commission
As regards the proposal for a directive on pay transparency, the LO is in favour of strengthening the tools to identify and address pay discrimination. The extensive Swedish practice concerning the Equal Pay Directive, the Equal Treatment Directive and others have not produced sufficient results, despite the fact that the legislation has been in place since the 1970s.
Filed in Swedish · English published by the European Commission
Equal pay for women and men is one of the cornerstones of Gender Equality and goes hand in hand with closing the gender care gap and supporting work-life balance. Hence closing the gender pay gap must be one of the key components of the next Commission’s Gender Equality Strategy, based on core European values of social inclusion and non-discrimination.
It is very important to pay attention to this issue. The European Union must take on the disparity, which is becoming increasingly apparent, in the remuneration given to women workers and given to men, women and men, who, for the same working hours, are paid differently and not by little, would in itself be a factor to be taken into account, but it must be borne in mind that that dynamic is a source of imbalances…
Filed in Italian · English published by the European Commission
The French authorities welcome this draft initiative of the European Commission on the transparency of pay between women and men. Indeed, the President of the Republic made equality between women and men the major cause of his five-year term of office 2017-2002 in order to achieve real equality.
Filed in French · English published by the European Commission
Whereas transparency is a crucial prerequisite for addressing unequal pay inequalities and discrimination; From a Swedish perspective, there is currently no need for further regulation at European level. Any further discussion must have as a starting point that any initiatives must respect, for example, the Swedish labour market model.
Filed in Swedish · English published by the European Commission
Ceemet, the European Tech and Industry Employers across the EU, supports the objective of reducing the pay gap between men and women. Actual pay discrimination between men and women is unacceptable – and already prohibited by existing EU and national legislation. In the general discussion, pay differences between men and women are however often mistaken with pay discrimination.
Suomen Yrittäjät (“Yrittäjät) is an interest and service organization for small and medium-sized enterprises (SMEs) and their owners. As Finland’s larg-est organization, representing 115,000 enterprises, we work every day to support free entrepreneurship and an entrepreneur-friendly society.
Strengthening the principle of equal pay between men and women through pay transparency The Swedish Association of Local Authorities and Regions (SALAR) is an employers' organisation and an organisation that represents and advocates for local government in Sweden. All of Sweden's municipalities and regions are members of SALAR.
KL is an employers’ organisation representing all 98 municipalities in Denmark. The 98 Danish municipalities have given KL the right to negotiate binding wage agreements and employment conditions for all employees in the municipal sector. The KL negotiates the agreement for approximately 500.000 employees with an annual wage bill of DKK 175 billion, which leaves KL to one of the biggest employers in Denmark.
Filed in Danish · English published by the European Commission
Parenthood and equally compulsory leave to tackle gender pay gap Wage differences between men and women have many causes, including different job participation rates, disparities between jobs and activities that still remain predominantly prerogative of either men or women. It often happens that women are forced to choose part-time working hours, in order to better balance between family care and their work.
For CEC European Managers, the European social partner organization representing the European managerial workforce, gender equality is fundamental. Improving the presence of women in the labor force, and especially in decision-making positions, is a priority that CEC has been focusing upon for many years. Gender pay gap is only one of the many ways in which discrimination is declined.
Closing the gender pay gap is an important challenge linked to many underlying factors. SMEunited is committed to promote the equal pay principle and to combat all forms of discrimination at the workplace. However, the gender pay gap is broader than the concept of equal pay for equal work or work of equal value, making it a complex issue to tackle.
The Confederation of Danish Employers shares the view of the European Commission that there is a case for addressing equal pay issues at the European level. Pay transparency can be a useful tool if it is used wisely. (1) Current EU law is clear The Commission states that it is necessary to clarify legal concepts related to equal pay, in particular the concept of “work of equal value”.
The Central Organisation of Finnish Trade Unions SAK ry attaches importance to this initiative. Urgent and sufficiently effective measures need to be taken to reduce the pay gap between women and men. In the first place, in order to reduce the pay gap, SAK considers it necessary to extend wage transparency so that all employees in the workplace are aware of pay and pay components (including management).
Filed in Finnish · English published by the European Commission
The Ministry of Taxation is an agency of the Ministry of Taxation, which is responsible for the role of the State employer. Employees and the Board of Competence are negotiating collective agreements in the territory of the State, which cover about 180.000 employees. In the context of this reply, the competent authority consulted the other employers in the public sector.
Filed in Danish · English published by the European Commission
Pay transparency is a tool against the gender pay gap, but it is not the final aim and it does not solve the internal causes of the gap. In fact, the underlying cause of the gender pay gap arises from the unequal distribution of unpaid care work. The wage gap between men and women cannot be solved without substantive action on care work, both paid and unpaid, most notably undertaken by mothers.
The European Chemical Employers Group (hereafter: ECEG) is the European Social Partner, representing interests of the employers from the chemicals, pharmaceuticals, rubber and plastics industries. As a Brussels-based social affairs organisation it is a consultative body for the European Commission, Parliament and other stakeholders.
With interest the Netherlands Institute for Human Rights has taken note of the European Commission’s initiative to assess the possibility of developing a binding instrument regarding pay transparency. In the attached letter the Institute means to inform you about the prevalence of wage discrimination in the Netherlands, recent policy developments and the work of the Institute in addressing the issue of wage…
The Confederation of Swedish Enterprise are staunch advocates for greater work life equality, see reports in attached file. It is our firm conviction that achieving greater gender equality is essential for the realization of the full potential of all individuals and undertakings. Research shows that workplaces where both men and women work achieve better business results and build better workplace communities.
ZDH, the German Confederation of Skilled Crafts and Small Businesses, is one of the leading associations of the German economy. ZDH is the roof association of 53 Chambers of Crafts, 49 craft trade associations and other institutions of the craft sector in Germany. ZDH represents the interests of 1 million companies, 5,5 million employees and around 360 000 apprentices.
EPSU welcomes the road map for the initiative “strengthening the principle of equal pay between men and women through pay transparency” because closing the gender pay gap is a matter of urgency and priority. For a detailed description of demands and concerns on this matter, EPSU would like to refer to its response to the public consultation held in November 2019.
MOL Group supports the initiative of strengthening the principle of equal pay between men and women. Gender being one of the four strategic pillars of MOL Group’s Diversity&Inclusion strategy together with age, wellbeing and changed working capacity.
The Federal Chamber of Labour thanks for the opportunity to provide feedback on the important issue of income transparency. We see gender equality as an essential element of a socially just society. Particular attention must also be paid to the unequal pay of women and men. Wage transparency is an important approach to tackling the gender pay gap.
Filed in German · English published by the European Commission
FH – Danish Trade Union Confederation strongly support the aim to strengthen the principle of equal pay between men and women. The struggle for equal pay is a high priority to our unions/member organizations and their members and is constantly at our aim. The Danish gender pay gap is approx. 15 percent, and although it has moved slightly in recent years, it is moving very slowly.
BDA is the leading organisation dealing with social policy on behalf of the entire German private sector. It represents the interests of small, medium-sized and large companies in all sectors and all issues linked to social policy and collective negotiations, labour legislation, labour market policy and education.
The National Commission for the Promotion of Equality acknowledges that pay transparency should be mandatory as it enables employees to identify discrimination and to access justice. Binding measures providing for transparency in pay and pay systems will indeed strengthen the implementation of the equal pay principle.
The Austrian Federal Economic Chamber (WKÖ1) is committed to the goal of reducing the gender pay gap. However, we are expressly opposed to mandatory pay reporting at European level. Austria has already introduced pay reporting for companies with more than 150 employees, which has resulted in a considerable additional administrative burden for these companies, as the preparation of such reporting has had to be…
JHL ry’s view on the need for a pay-transparency directive JHL ry attaches great importance to the initiative. Effective measures are urgently needed to reduce the pay gap between women and men. Wage knowledge plays an important role both in promoting equal pay and in detecting pay discrimination.
Filed in Finnish · English published by the European Commission
Very often, too often, in job advertisements — in Italy — pay is not declared, it is said that it will be ‘commensurate with the candidate’s actual experience and competence’ and that if the candidate is male at the end of the interviews, the employer’s offer will be greater than for a female candidate.
Filed in Italian · English published by the European Commission
HOTREC is the umbrella Association of hotels, restaurants, bars and cafés in Europe, which brings together 45 national associations in 33 European countries. Please find in the document enclosed HOTREC's contribution to the Commission roadmap on the inception Impact Assessment on "Strengthening the principle of equal pay between men and women on pay transparency"
Method. Every quote is verbatim from the organization’s own submission to the European Commission, trimmed to its opening passage and never summarized by a model. Where a submission was filed in another EU language we show the English text the European Commission publishes alongside it, labeled on the quote; the original is one click away at the source. Groupings use the respondent type the organization itself selected when filing. We deliberately do not label anyone “supportive” or “opposed” — you read what they wrote and draw your own conclusion. Organizations only, never individuals. Reused under Commission Decision 2011/833/EU; the European Commission is not liable for this reuse.