• The obligation for companies to keep a salary register comes into force on 14th April  
  • The obligation for companies with over 100 employees to implement a gender equality plan and conduct a pay audit came into force this month (March 2021).  


March 2019 saw the publication of Royal Decree-law 6/2019, setting out the obligation for all companies with over 50 employees to implement a gender equality plan. The law introduced a number of new features to be enforced gradually, depending on the number of employees in a company’s workforce.

The obligation to implement a gender equality plan currently affects companies with at least 150 employees, with the threshold to be reduced to 100 employees by March 2021, and to 50 in March 2022.

However, the gender equality plans and pay audits, among other matters, were awaiting further regulatory development, which arrived in the shape of the publication, on 14 October last year, of Royal Decrees 901/2020 and 902/2020, developing and regulating gender equality plans, introducing important new obligations for companies, and setting the time limits for compliance.

Royal Decree 901/2020, regulating gender equality plans and records, came into force on 14 January 2021, and requires the affected companies to implement a gender equality plan in line with its provisions.

It also provides details on the key points to bear in mind when developing and implementing gender equality plans. The text sets out the minimum requirements in terms of the content, how to make workforce calculations, the obligation to conduct a pay audit as part of the plan, implementation deadlines, competence of the negotiation committee, among other matters, as well as its period of validity, which may not exceed four years.

Meanwhile, Royal Decree 902/2020, on gender pay equality, comes into force on 14 April 2021. All companies are required to keep a salary register in compliance with the new legislation, regardless of the number of employees.

This requirement consists of carrying out a pay analysis on the company’s entire workforce. It should be differentiated by gender and include the average salaries, supplements, and fringe benefits, to ensure that the company’s equal pay policy is effectively implemented. The register should have an estimated duration of one year.

The team at Bové Montero y Asociados is at your service to discuss any doubts or questions you may have in this regard. We can help your company to develop and implement and gender equality plan and create a salary register with a view to complying with the latest employment regulations.


Contact our team:

José Luis Gómez

José Luis Gómez, Labour Manager, Barcelona
Email: jlgomez@bovemontero.com
Tlf.: +34 932 18 07 08

Yolanda Pueyo

Yolanda Pueyo,Labour Manager, Madrid
Email: ypueyo@bovemontero.com
Tlf.: +34 915 61 54 14