Spain's Registro Retributivo — Mandatory Pay Registers and Equal Pay Audits (Real Decreto 902/2020)

Spain's persistent gender pay gap and a 2019 requirement for equality plans led the government to adopt Real Decreto 902/2020, on equal pay between women and men, in force since April 2021.
The decree creates three linked instruments: a universal pay register, disaggregated by sex, professional category and pay component, that every employer must keep; a mandatory, gender-neutral job evaluation for companies required to have an equality plan (progressively extended down to firms with 50+ employees); and a pay audit obliging employers to justify any gap of 25% or more in pay for work of equal value (a 2026 draft amendment, now in public hearing, would lower that threshold to 5%).
INE's Annual Wage Structure Survey shows the unadjusted gender pay gap falling from 18.72% in 2020 to 17% in 2022 and 15.74% in 2023 (average annual wages of EUR 30,372 for men versus EUR 25,591 for women), a faster decline than in the pre-decree decade. Independent legal analysis confirms the obligations became mandatory nationwide and are now being tightened rather than relaxed. This trend is documented but not causally isolated from other factors such as minimum-wage increases; Spain also missed the June 2026 deadline to transpose the EU Pay Transparency Directive, showing implementation is still evolving.
The register-plus-threshold-audit design is one of the reference models behind the EU Pay Transparency Directive (2023/970/EU), which all 27 EU member states must transpose by June 2026, giving the approach direct cross-border replicability.

Read the full analysis: https://bloglaboral.garrigues.com/en/royal-decree-on-equal-pay-for-women-and-men-takes-effect-in-spain-with-three-instruments-job-evaluations-pay-registers-and-pay-audits