The Annual Salary Register

In the last years, the principle of gender equality has been given an enhanced role in Spanish labour law. In October 2020, two important regulations were approved; the Royal Decree 901/2020 and the Royal Decree 902/2020, which regulate equality plans, audits and a public salary register.


Explore the new regulations on the salary register and compensation audit, designed to address gender pay disparities in the workplace. From mandatory requirements to consequences of non-compliance, delve into the essentials of these measures shaping modern employment practices.

Here you will find everything you need to know about the new regulations.

What is the salary register?

The salary record will serve to collect information on gender pay in the different professional categories and allow the development of corrective measures to achieve workforce without gender inequalities.

Which companies have to prepare the salary register?

All companies must prepare the salary register without exception, independent of size or turnover. So, even if you employ only one male or one female employee, the register still is compulsory, even if this sounds a bit ridiculous.

On the other hand, if you, as the administrator shareholder of the company are the only employee and you are in the RETA regime, the register is not needed.

What is a compensation audit?

The Compensation Audit consists of compiling and analyzing information about the employees’ remuneration. The purpose is to show any pay gaps that might exist and apply measures to ensure that the compensation structure of the company follows the principle of equality between men and women in terms of salary.

Which companies have to prepare the compensation audit?

Companies with the obligation to prepare an Equality Plan (those with 50 or more employees), must additionally conduct a Compensation Audit.

What should the salary register include?

It must include a gender breakdown between the average and the median of the actual compensation, allowances and non-wage payment for each occupational group, professional category, level, position, or any other applicable classification.

Can i make the salary register and the compensation audit by job groups or categories?

No, it must be a single record for the entire company. It should refer to your entire workforce, including senior management and senior positions, even if they belong to different sections of the job classification.

How to present the salary register:

If there are workers’ representatives

The Salary Register must be sent to the legal representative of employees. They have the right to know the full content of the registry. In addition, the representatives must be consulted, at least 10 days in advance, prior to the preparation of the registry (also if there are any modifications).

If there are no workers’ representatives

In this case, the information is to be provided on request and will be limited to the percentage differences that exist in the average salaries of men and women. When the Salary Register shows that there is a pay gap higher than 25%, the company will have to justify that this difference is not due to gender.

What are the consequences if i do not follow the regulations?

Investigations are started when a complaint is made by the Labour Inspectorate. Not following this obligation is considered to be a serious infringement according to the social order law articles 7.5 and 13 and can be sanctioned with a fine between €751 to €7.500. It will also void any subsidies or employment supports received.

Do you want us to prepare your salary register?

We are happy to prepare your annual salary register for you if you would like us to do so. For more information, feel free to contact us. We’re here to assist you! Contact Us


The information contained herein is of a general nature, and subject to changes. Applicability to your specific situation should be determined through consultation with our tax or legal advisors.