Spain has the European Union's clearest job-evaluation mandate. Royal Decree 902/2020 requires employers to value jobs using a defined factor system governed by three legal criteria — adequacy, completeness and objectivity — to underpin a compulsory pay audit. Employers with 50 or more staff must comply.
Spain has gone further than any other EU member state in legislating job evaluation. Real Decreto 902/2020 on equal pay between women and men (in force since April 2021, developing Article 28 of the Workers' Statute) makes pay transparency operational through two instruments — and puts a formal job valuation underneath both.
First, every employer must keep a registro retributivo (pay register) with sex-disaggregated averages and medians of salaries, salary supplements, and extra-salary payments across the workforce. Second — and this is where the mandate bites — companies with 50 or more employees must conduct a pay audit (auditoría retributiva) as part of their equality plan. The audit legally requires a prior valoración de los puestos de trabajo: a valuation of every job, because the register must report its data grouped by jobs of equal value, and the equality-plan diagnosis must rest on that grouping.
Article 4 of the Decree sets three statutory quality criteria for any valuation system: adecuación (the factors used must reflect the actual activity performed), totalidad (every relevant value factor must be captured, with none ignored), and objetividad (criteria must be verifiable and gender-neutral). To make this concrete, Orden PCM/1047/2022 approved and published an official job valuation procedure with an accompanying tool — the SVPT job evaluation workbook, published with an English user guide. It is voluntary to use, but a clear statement of what the regulator considers a compliant methodology: factor-based, weighted, documented. The ministry also publishes an official pay register template for the registro retributivo.
The obligations apply across the private sector, and works councils have a statutory role: where unjustified pay differences of 25% or more appear, employers must justify them.
Spain enforces through the Labour Inspectorate, with equality-plan and pay-register breaches sanctionable under the LISOS infraction regime — and, just as practically, through the courts: a valuation that fails the adequacy/completeness/objectivity test undermines the employer's defense in any equal-pay claim.
Spain's framework also positions it well for the EU Pay Transparency Directive: the Directive's requirement that pay structures rest on objective, gender-neutral criteria — skills, effort, responsibility, working conditions — is substantially what RD 902/2020 already demands. Spanish employers who built a compliant valuation are most of the way to Directive readiness; the Directive adds reporting thresholds, joint pay assessments, and stronger worker information rights on top.
Spain is the rare jurisdiction where the regulator has effectively published a reference job-evaluation method. The official PCM/1047/2022 procedure is recognizably a point-factor system: decompose jobs into factors, weight the factors, score every job, and group jobs into equal-value sets.
For employers, a structured point-factor platform delivers exactly the artifacts Spanish law demands:
In Spain the question is no longer whether to value jobs, but whether your valuation would survive an inspector reading it next to the official procedure.
Government-published job evaluation tools, guides, and templates — each links directly to the official source.
The Sistema de Valoración de Puestos de Trabajo published under RD 902/2020 and Orden PCM/1047/2022. Voluntary, but the regulator's reference methodology.
Official template for the pay register every Spanish employer must keep.
Yes, for employers with 50 or more employees. Royal Decree 902/2020 requires them to run a pay audit (auditoría retributiva), and the audit must be built on a prior job valuation (valoración de puestos de trabajo) that meets three legal criteria — adequacy, completeness, and objectivity. Spain is the EU's clearest explicit job-evaluation mandate.
A pay register that every Spanish employer — regardless of size — must keep, showing averaged salary data disaggregated by sex across the workforce. For companies that must run a pay audit, the register must additionally group results by sets of jobs of equal value, as determined by the job valuation.
Article 4 of RD 902/2020 requires the valuation system to satisfy adequacy (adecuación — factors must reflect the actual work), completeness (totalidad — no relevant value factor may be ignored), and objectivity (objetividad — criteria must be verifiable and gender-neutral). Orden PCM/1047/2022 publishes an official valuation procedure and tool employers can use.
No — the procedure and spreadsheet tool published by Orden PCM/1047/2022 are voluntary. Employers may use their own valuation methodology as long as it meets the adequacy, completeness, and objectivity requirements of RD 902/2020.
PointFactors implements the analytical, factor-based methodology referenced by pay equity laws worldwide.
Book a DemoInformational summary of legal requirements, not legal advice. Verify against primary sources before relying on it.
Last reviewed: 2026-06-11