Why Job Titles Matter for EU Pay Transparency (and What to Do if Yours Are a Mess)

One of the most common issues we see when helping companies prepare for EU pay transparency is that they need to change their job title system. This may be a case of tweaking titles to standardise them, or it could mean a major overhaul. Here’s why job titles matter when it comes to preparing for salary transparency, how they impact pay equity analysis and pay gaps, and what to consider if you're planning job title changes.

How Do I Know if I Have a Job Title Problem?

At the heart of the EU Pay Transparency Directive is the concept of equal pay for work of equal value. To meet this requirement, companies must categorise jobs based on objective, gender-neutral criteria - namely, skills, effort, responsibility, and working conditions.

This means that roles requiring the same types of skills, and the same level of responsibility and effort, performed under the same or similar working conditions sit within the same job category. 

Many organisations are currently in the middle of this job evaluation process, aligning roles to categories ahead of the directive coming into effect in June 2026. 

Typically, the process involves:

1. Reviewing and standardising job descriptions.

2. Categorising roles based on objective factors.

3. Comparing compensation within and across job categories.

4. Identifying any unexplained pay gaps of 5% or more - these must be either objectively justified or corrected.

Pay Transparency and Job Titles: What You Might Discover Along the Way

Once job categories and pay gaps are mapped out, companies often notice a few patterns:

• Different titles, same job: it’s common to find people with different job titles who are effectively doing the same work. For example, a ‘Customer Success Manager’ and a ‘Client Relationship Specialist’ might fall into the same category - even if the titles suggest different things.
  
  

• Same title, different work: conversely, you might have people with the same job title whose work varies significantly - one might have more responsibility or manage a team, while another does not.
  
  

• Inconsistent pay within a title: if pay differs widely among people with the same title and similar job responsibilities, it raises red flags for bias, pay inequity, or inconsistent compensation practices.

What to Do When Issues Emerge

Job title inconsistencies are more than an HR housekeeping issue - they can obscure pay disparities, make job evaluation harder, and weaken your compliance position under the EU Pay Transparency Directive.

Here’s how to fix these issues:

1. Standardise Your Job Titles

Establish a clear naming convention across the organisation. Use titles that reflect the nature and level of the role (e.g. Specialist, Manager, Senior Manager). Avoid inflated or overly creative titles that make job comparison difficult.

The EU Pay Transparency Directive states that job titles must be gender neutral to disrupt the continuation of the gender pay gap over time. Think firefighter, cabin crew and police officer instead of fireman, air hostess and policeman.

Job titles also tell your customers, suppliers, and strategic partners something about the person they’re dealing with. For example, Chief Happiness Officer is a real job title, but it doesn’t help us fully understand the role. You may want to refer to industry job title standards to help people quickly understand your company’s roles.

2. Map Titles to Clear Role Descriptions

Every job title should be linked to a well-defined, up-to-date role profile. Include the required skills, level of responsibility, reporting lines, and working conditions. This ensures roles can be accurately categorised and compared. 

3. Consolidate Where Appropriate

If multiple titles represent the same work, consider consolidating them under a single, standard title. This reduces complexity and strengthens the integrity of your job categorisation and job architecture. It also means fewer roles and role descriptions for HR and leaders to manage. 

4. Differentiate When Necessary

If people with the same title are doing materially different work, it’s time to split that role into separate titles or levels. Clear differentiation helps maintain fairness and avoid misleading pay comparisons. What counts as materially different? A good rule of thumb is an 80/20 split - if more than 80% of the role is different, split the roles apart.

5. Communicate Transparently

Job title changes can feel personal. Be sure to explain why you’re changing them - especially if changes are part of broader salary transparency or pay equity goals. Emphasise that the goal is fairness, not hierarchy, and that the job title is one element of ensuring jobs are evaluated fairly.

6. Maintain Job Titles and Job Levelling Structures

Once you’ve harmonised your job titles, put a clearly defined process in place to maintain the consistency of your job titles and job architecture. Creating or approving job titles is likely to be a task that sits with HR to ensure consistency.

What Does ‘Good’ Look Like?

In a well-structured job architecture, job titles:

• Are standardised and meaningful across departments
  
  

• Clearly align with consistent job descriptions
  

• Map logically to your job evaluation framework and job architecture
  
  

• Help rather than hinder pay equity analysis
  

• Are communicated and understood internally because they reflect the context and specifics of your business

When job titles are clean, consistent, and aligned with role content, it becomes far easier to evaluate jobs fairly, explain pay decisions, and demonstrate compliance with pay transparency regulations.

Final Thoughts on Pay Transparency and Job Titles

Fixing job titles may not feel urgent, but it’s foundational for your salary transparency journey. Not only will it impact how easy it is to evaluate jobs and carry out pay equity analysis, ultimately, it will determine how credible your reporting is.

In short: if your job titles are messy, your pay data might be misleading. Clean titles mean clean data. And clean data means a stronger, fairer, more compliant organisation.

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