The salary register (or “registro retributivo”) has been a mandatory document for every company with staff in Spain, regardless of size, since April 2021. It records the average and median salaries, salary supplements and non-salary payments for the entire workforce, broken down by gender and by professional group or job category, and job of equal value where the company has a registered Equality Plan. On paper it sounds simple, but in practice it’s one of the obligations that raises the most questions. Here are the most common difficulties, and how to approach them.
What exactly does the law require?
The Royal Decree 902/2020, on equal pay between women and men, states that every company must keep a register covering the entire workforce, including management and senior executives. It must reflect all payments, both salary and non-salary, whether in cash or in kind.
It isn’t a document that gets filed or registered with any authority: the company itself prepares and keeps it, and it must be kept up to date. In addition, when the average or median total pay for one gender exceeds the other’s by at least 25%, the register must include a justification showing that the difference is not related to gender.
The 6 most common difficulties
1. Data scattered across different systems. Base salary, bonuses, commissions, variable pay and benefits in kind are usually held in different tools. The practical solution is to use payroll as the single source of truth and cross-check it against everything else, so the register matches what was actually paid.
2. Defining what counts as a “job of equal value”. This only comes into play if the company has a registered Equality Plan (mandatory from 50 employees upward, though any company can register one voluntarily); in that case, the law requires comparing jobs of equal value and doesn’t offer a fixed formula for defining them. The recommendation is to base this on duties, required training and working conditions, and to document the criteria applied.
3. Correctly classifying each pay item. Telling salary items apart from non-salary ones, and deciding how to treat benefits in kind or executive pay, is a common source of errors.
4. Standardizing working hours and periods. Part-time schedules, hires and leavers during the year, or role changes, all require adjusting the data so it’s comparable. The law requires the analysis to use actual amounts paid, although it’s advisable to have all the data standardized to properly analyze any gaps.
5. Interpreting the results and justifying differences. Spotting a significant difference is only the first step: you then need to analyze its cause and document an objective justification.
6. Keeping the register up to date. A register prepared once and then forgotten loses its value. It should be reviewed every year using the previous year’s pay data, and whenever there are substantial changes, such as new hires, collective agreement updates or restructuring.
How to approach it, step by step
- Centralize the data on pay for the entire workforce in a single place.
- Define and document the criteria used for grouping (professional groups, categories or jobs of equal value).
- Calculate averages and medians by gender and by group.
- Review the differences and identify which ones require justification.
- Plan for periodic updates so you’re not caught off guard at the next review.
Many salary register issues start with errors further upstream, in payroll itself. If you’d like to review the ones that cause the most problems, our article 9 Common Payroll Errors and How to Avoid Them goes through them in detail.
Frequently asked questions about the salary register
Is it mandatory for every company? Yes. The obligation applies to every company with staff in Spain, regardless of size.
Does it have to include management? Yes. The register covers the entire workforce, including management and senior executives.
Does it have to be published? No. It isn’t a document that gets registered or made publicly available. The company must prepare it, keep it on file, and give access to employees’ legal representatives.
How often does it need to be updated? It must be kept up to date. In practice, it’s reviewed every year using the previous year’s data, and whenever substantial changes occur.
What happens if I don’t have one? Non-compliance can lead to penalties from the Labor Inspectorate.
How ROSCLAR can help
Preparing the salary register requires spotless payroll and well-structured data. At ROSCLAR, we’ve spent almost two decades managing payroll for Spanish and international companies in Spain, so we start from information we’re already handling every month. We help you gather it, organize it and turn it into a clear, up-to-date register that’s easy to maintain, with a single point of contact who knows your business.
👉 Want to check whether your salary register is up to date? Get in touch with our team.