A few months ago, Royal Decree-Law 902/2020 of October 13 was published, which develops the already existing obligation to carry out the salary record, incorporating more details and new deadlines. The real obligation begins on April 13, 2021, when all companies must carry out the Salary Register.
The remuneration register is a document where all the company’s salary information must be recorded in detail, thus separating the remuneration of men and women from the workforce, also taking into account the management staff and senior positions.
On the other hand, in article 4 of this RDL, the obligation of equal pay for work of equal value is regulated. What does it mean? Those who perform the same functions/tasks with the same working conditions and demand the same professional or training requirements for their performance.
In addition, the principle of remuneration transparency must be applied in these records, as well as in the remuneration audits and job evaluation systems that the standard also includes. The purpose of this principle will be to identify direct or indirect discrimination concerning job evaluations when performing work of equal value; a lower salary is received without any justification.
What should the record include?
- Total annual salary and gender gap of this concept
- Annual base salary and gender gap of this concept
- Annual salary supplements and gender gap of this concept
- Extra-salary earnings (if any) and gender gap of this concept
- Annual earnings for overtime and gender gap for this concept
All this will have to be broken down by professional category and by sex. In addition, an average of what is actually established by each professional group will have to be established, that is, for jobs of equal value. The reference period will be one calendar year, so 2021 will have to correspond to the year 2020.
The workers’ legal representative should be consulted 10 days before preparing the record and before modifying it. In the event of any anomaly or bad practice in equal pay, the company must include in the registration document what measures it will apply to rectify those circumstances.
Which workers will have access to the salary register?
Workers will be able to access the salary register through the workers’ representatives to know the content. In the absence of legal representation or committee, the information provided to workers will be limited to percentage differences that may exist between men and women.
What penalties can be applied to me if I do not have a salary record?
The RDL establishes that if it is the case that the company does not have the salary record or falsifies the data (manipulating them so that the reality is different), depending on the seriousness of the facts that the Administration can interpret, the fines will range between €6,251 and €187,515.
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